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FILED
DALLAS COUNTY
1/6/2020 10:51 AM
FELICIA PITRE
DISTRICT CLERK
Treva Parker—Ayodele
N0. DC-19-16024
SARAH MARTINEZ § IN THE DISTRICT COURT
PLAINTIFF, §
§
VS. § DALLAS COUNTY, TEXAS
§
RUDY SANCHEZ §
DEFENDANT § 298TH JUDICIAL DISTRICT
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE T0 PLAINTIFF’S
REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS
Pursuant t0 TeX R. CiV. P. 194, Defendant serves the following First Supplemental
Response to Plaintiff s Request for Disclosure and Designation 0f Experts.
f. For any testifying expert:
1. The expert’s name, address, and telephone number;
2. The subj ect matter 0n Which the expert will testify;
3. The general substance 0f the expert’s mental impressions and opinions and
a brief summary of the basis for them, or if the expert is not retained by, employed by, 01‘
otherwise subject to the control 0f the responding party, documents reflecting such
information;
4. Ifthe expert is retained by, employed by, 0r otherwise subject t0 the control
0f the responding party:
A. A11 documents, tangible things, reports, models, 0r data
compilations that have been provided to, reviewed by, or prepared by or for the
expert in anticipation 0f the expert’s testimony; and
B. The expert’s current resume 0r bibliography.
Response: Defendant hereby designates and reserves the right t0 call any expert Witness(es)
designated by any other party to this case, as well as any experts later designated
by any party t0 this case 0n any subject relevant t0 this litigation 0n Which the
witness is qualified to testify. In the event that any party to this cause has
designated any experts but has been or is subsequently dismissed for any reason or
fails t0 callany designated expert at the time 0f trial, Defendant specifically
reserves the right to call any such expert previously designated by that party.
Defendant further reserves the right t0 withdraw 0r de-designate any expert prior
t0 testimony and t0 positively aver that such previously designated expert Will not
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1-
be called as a witness at trial and to redesignate same as a consulting expert who
Will not be called by any party in this cause. Finally, Defendant reserves the right
to supplement this response as additional information concerning experts becomes
available.
Defendant further hereby designates as adverse expert Witnesses all expert
witnesses designated by Plaintiff. Defendant reserves the right to rely upon or to
offer, by direct examination or cross-examination, testimony obtained from those
experts and rebuttal experts, if any, designated by Plaintiff. By this designation,
Defendant does not necessarily agree with, nor vouch for, the credibility of any
such Witnesses 0r their opinions, or the reliability, materiality, or admissibility of
information and/or tangible things produced by these individuals in general; by this
designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit
certain opinions and/or evidence from these witnesses t0 the extent that it deems it
in its interest t0 d0 s0.
Such persons are expected to testify concerning Plaintiffs care and treatment. See
Plaintiffs Responses to Defendant’s Request for Disclosure for additional
information concerning such health—care providers including medical bills and
records relating to Plaintiff.
First Supplemental Response:
Defendant hereby designates as an expert witness the following individual:
Joseph Klotz, DC
7700 Eldorado Pkwy., Suite 100
McKinney, TX 75072
972.540.0608
Dr. Klotz is a chiropractor who has reviewed Sarah Martinez’s medical records and other
case materials provided to him, and is expected t0 testify regarding the extent 0fthe injuries
sustained by the Plaintiff in the subject motor vehicle accident, the appropriate care and
treatment for those injuries, and the fair and reasonable cost of that treatment, both in the
past and in the future, if applicable, as set out in the attached report.
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2-
Respectfully submitted,
?Mfivfl—g,
Chad Kimble, Bar N0. 24007483
State
Kyle Smith, State Bar No. 24102512
D. Brent Beasley, State Bar No. 24082669
LAW OFFICE 0F CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANT
CERTIFICATE 0F SERVICE
The undersigned certifies that on the 6th day 0f January, 2020, a true copy of the foregoing
has been served 0n all patties in accordance With Rule 21a, Texas Rules 0f Civil Procedure.
96.1%
Brent Beasley
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3-
JOSEPH KLOTZ, D.C. 12001 N. CENTRAL EXPRESSWAY
DOCTOR 0F CHIROPRACTIC SUITE 800
DALLAS, TX 75243
(214) 750-61 10
FAX —
(21 4) 750-5825
December 27, 201 9
Mr. Chad Kimble
Low Chad Kimble, P.C.
Office of
1204 Sou’rh Whi’re Chapel Blvd.
Sou’rhloke, TX 76092
Fox: 81 7-423—7492
RE: Sarah Martinez
CLAIM #: 0490698486
DATE OF INJURY: 12/04/1 7
CASE #2 210031 18
Dear Mr. Kimble:
| hove had The opporTuniTy ’ro review medical records on Ms. Soroh Martinez.
My name is Joseph Klo’rz, DC. om
licensed by The s’ro’re of Texas as 0 Chiroprocfor.
| hove nine years of |
experience Treating pofien’rs as o Chiropractor
in The s’ro’re of Texas. hove practiced in The DFW area for seven
|
years 0nd Son An’ronio for Two years. also hove undergone formal Designo’red Doc’ror Training in The s’ro’re of
|
Texas 0nd om awaiting To si’r for cerTificoTion ’res’ring for The purpose of evoluo’ring injury cases. In my nine years
of experience, | hove Treo’red Thousands of po’rienfs wi’rh complaints of pain in The spine 0nd from
ex’rremi’ries
mo’ror vehicle accidents or o’rher injuries. | commonly coordinate core wi’rh o’rher specialists ’ro ensure quoli’ry
0nd efficiency of core for The po’rien’r. om
experienced wi’rh The cos’rs involved wi’rh
| occiden’r cases 0nd
ore ossocio’red wi’rh These cases.
’rreo’rmen’rs Tho’r
My commen’rs on reasonable 0nd necessary allowances ore based Upon my years of experience in Treating
injury potienTs. | regularly coordinate core wi’rh o’rher providers To assure my po’rienTs
The quoli’ry core They ge’r
con afford. om very familiar wi’rh fee schedules for common TreonenT codes Ground The oreo. Reasonable
|
0nd necessary charge recommendo’rions ore based Upon usual 0nd customary fees Ground The region.
OVERVIEW
The patient is o female Tho’r wos involved in o motor vehicle occiden’r on December O4, 201 7.
On January 30, 2018, ’rhe patient presented ’ro Accident & Injury Chiropractic for evoluo’rion 0nd Treatment of
mid back pain 0nd low back pain. Range of mo’rion in The Thorocolumbor spine is res’rric’red 0nd posi’rive for pain.
Or’rhopedic ’res’ring showed The following posi’rive ’res’rs: SLR [S’rroigh’r Leg Raise]. Neurological Testing is wi’rhin
normal limi’rs wi’rh The excep’rion of diminished reflexes symmetrically o’r C5, C6, 0nd L4. Reflexes were no’r
performed CIT C7 0nd S1. Streng’rh 0nd sensory ore normal. Clinical impression: Sproin/S’rroin Thoracic, lumbar;
Myofosci’ris; Segmental Dysfunc’rion Thoracic, lumbar; Sposm; Pain Thoracic, lumbar; S’riffness of Join’r Thoracic,
lumbar. Plan: rehabili’ro’rion.
Sarah Martinez
December 27, 20] 9
CASE #2 210031 18
Page 2 of 4
OPINION
Acciden’r & Iniurv Chiropractic:
In reference ’ro ’rhe exam, ’rhe CPT Coding Manual requires Three key components: o de’roiled
use of c1 level |||
his’rory, c1 de’roiled exam, 0nd
low level of medical decision—moking. In oddi’rion, ’rhe problem severi’ry should
c1
be moderate, 0nd physician Time up ’ro Thir’ry minu’res. From The documentation provided, appears This cri’rerio i’r
hos been me’r, 0nd ’rhe service is Therefore necessary on January 30, 2018.
In reference ’ro ’rhe use of o level re—exom, ’rhe CPT Coding Manual requires ’rwo of ’rhe Three key components:
||
o problem focused his’rory, o problem focused exam, 0nd s’rroigh’r forward medical decision—moking. In addition,
’rhe problem severity should be seIf-Iimi’red or minor, 0nd physician ’rime o’r Ieos’r ’ren minu’res. Based on my clinical
experience wi’rh sof’r Tissue relo’red injuries, re—exomino’rion is worron’red every six visi’rs ’ro determine confinued
need of core vs medical discharge. From ’rhe documen’ro’rion provided, appears ’rhis criteria hos no’r been me’r, i’r
0nd ’rhe level re—exom was therefore no’r reasonable 0nd no’r medically necessary on February 01, 2018, cs o
||
new po’rienT level exominofion wos performed The previous visiT. From The documen’ro’rion provided This service
|||
did mee’r The following requirements 0nd was therefore reasonable 0nd necessary on March 20, 201 8.
In reference ’ro The use of o level re—exom, The CPT Coding Manual requires Three key componenTs: o deToiled
|||
hisTory,o deToiled exam, 0nd o modero’re level of medical decision—moking. In addition, The problem severi’ry
should be modero’re, 0nd physician Time 0T Ieos’r Thir’ry minutes. Based on my clinical experience wi’rh sof’r Tissue
relo’red injuries, re—exomino’rion is worron’red every six visi’rs ’ro determine continued need of core vs medical
discharge. From The documentation provided, appears This cri’rerio hos been me’r, 0nd The level
i’r re—exom was |||
therefore reasonable 0nd necessary on February 19, 2018. From The documentation provided, The following
requirements were no’r me’r 0nd ’rhe following dates of service were bo’rh no’r reasonable 0nd no’r medically
necessary on March 21 201 8, os o level examination was performed one day before. Additionally, The following
, ||
do’re of service did no’r mee’r ’rhe requirements, April 17, 2018, Gs ’rhe po’rien’r should hove already been
discharged o’r ’rhis poin’r.
In reference The chiropractic adjustment, from my experience wi’rh The diagnosis of This po’rien’r, o Trial period
’ro
of Treo’rmen’r consisting 2—3 weeks hos been indicated ’ro provide 0n adequo’re sample of ’rhe success of ’rhe
’rreo’rmen’r. If The chiroproc’ror con demons’rro’re objec’rive functional improvement during The Trial period, Then
up ’ro 18—22 Treo’rmen’rs over o period of six weeks is recommended. In ’rhis case, There was objecTive func’rionol
improvemenf during The Trial period of core. Therefore, ’rhe Ios’r do’re of service should hove been March 13, 20] 8,
0nd no’r April 12, 2018.
In reference To The use of Theropeufic exercises, based on my clinical experience wi’rh sof’r Tissue relo’red injuries,
| recommend up ’ro Ten sessions over on eighT—week period. The proc’ri’rioner should allow for fading of Treo’rmenT
frequency from Three visi’rs perweek To one or less, wi’rh on emphasis on oc’rive seIf—direc’red home PT. If objec’rive
functional improvemen’r during The firs’r ’ren sessions is documented, Then recommend up ’ro eigh’r more sessions. |
In This case, There wos objective functional improvement during The ’rriol period of core. Therefore, The IosT doTe
of service should hove been April 05, 2018, 0nd no’r April 12, 2018.
From myexperience wi’rh ’rhe fee schedules Ground ’rhe DFW oreo, ’rhe charges for ’rhe services below were
excessive. The below shows ’rhe omoun’r billed for each service 0nd c1 range of ’rhe reasonable charges for
Iis’r
each: Billed U&C Range
Level ||| Exam $325.00 $1 00.00 -
$1 60.00 X 1
Level || Re—Exom $1 60.00 $70.00 -
$100.00 X 1
Level ||| Re—Exom $204.00 $80.00 -
$1 20.00 X 1
CMT 1—2 $96.00 $50.00 —
$70.00 X 17
CMT 3—4 $1 06.00 $65.00 —
$85.00 X 1
Therapeutic Exercises $98/uni’r $40.00 -
$60.00/uni’r x 18
Sarah Martinez
December 27, 20] 9
CASE #2 210031 18
Page 3 of 4
The ’ro’rol reasonable charges for ’rhe necessary Treatment including imaging ore between $1 ,885 0nd $2,735.
Based Upon my review of ’rhe cloimon’r’s medical record, is my opinion wi’rhin o reasonable degree of
i’r
medical probability along wi’rh my experience, Training, education 0nd knowledge in Treating po’rien’rs wi’rh
similar complaints Gs This cloimon’r, Tho’r ’rhe patient will no’r require any fu’rure medical Treo’rmen’r for The injuries
sus’roined by The individual in The mo’ror vehicle accident.
Thank you for The opportunity ’ro review The medical records on Ms. Sarah Morfinez.
Dic’ro’red, reviewed, opinion verified, 0nd o’r’res’red ’ro by my original signo’rure.
Sincerely,
///
Joseph Klo’rz, D.C.
Doc’ror of Chiroproc’ric
1 1470
JK/ck/pl
The opinions rendered in ’rhis case ore ’rhe opinions of ’rhe evoluo’ror. This review hos been conduc’red on ’rhe
basis of ’rhe medical records provided, wi’rh ’rhe assumption Tho’r ’rhe material is ’rrue 0nd correct. If more
information becomes available 0T a Io’rer do’re, on additional service/repor’r/reconsidero’rion may be requested.
Sarah Martinez
December 27, 2019
CASE #: 21003118
Page 4 of 4
SUMMARY OF RECORDS
Dallas Fire-Rescue: 12/04/17
Baylor University Medical Center ED: Wendy Wong, M.D./Ali Farzad, M.D., 12/04/17 - 02/05/17
(Chiropractic Evaluation & Treatment, un-documented facility/provider name illegible): 01/30/18,
02/01/18, 02/02/18, 02/05/18, 02/06/18, 02/08/18, 02/09/18, 02/10/18, 02/13/18, 02/14/18, 02/19/18,
02/21/19, 02/23/18, 02/26/18, 02/27/18, 02/28/19, 03/05/18, 03/06/18, 03/09/18, 03/12/18, -3/13/18,
03/20/18, 03/21/18, 03/23/18, 03/26/18, 03/27/18, 03/28/18, 04/09/18, 04/11/18, 04/12/18
(Accident & Injury Chiropractic), patient participated in chiropractic therapy 02/01/18 – 04/25/18),
undocumented provider – 04/25/18
Musculoskeletal Exam (undocumented facility): 03/01/18, 04/17/18
RolleLaw, To: 29th District Court, George L. Allen, Sr., Courts Building: 12/12/19
Affidavit of Medical Charges from Baylor University Medical Center: 11/06/19
Affidavit of Medical Records from Baylor University Medical Center: 06/05/18,
Medical Records Affidavit, Baylor University Medical Center, Dates of Service: 06/05/18
Affidavit of Necessity of Services/Reasonableness of Charges, Accident & Injury Chiropractic: 10/21/19
Affidavit of Medical Records, Accident & Injury; Affidavit for Authorization of Business Records: 10/21/19
Black & White copy Texas Under 21 Driver License: (name illegible)
Affidavit of Medical Charges from City of Dallas EMS/Affidavit of Medical Expense: 11/15/19
Affidavit of Medical Charges from American Radiology Consultants: (undated)
MSN Affidavit for American Radiology Consultants: 11/05/19
Affidavit of Medical Charges from Century Integrated Partners, Filed: 12/12/19
Affidavit of Medical Charges, Century Integrated Partners: 10/25/19
Affidavit of Necessity of Services/Reasonableness of Charges, Accident & Injury Chiropractic: 10/21/19
Affidavit for Authentication of Business Records, Accident & Injury Chiropractic: 10/21/19
Affidavit of Medical Expenses, City of Dallas EMS: 11/15/19
MSN Affidavit for (billing records), American Radiology Consultants: 11/05/19
Affidavit of Medical Charges, Century Integrated Partners: 10/25/19
Itemized Statement: Baylor University Medical Center, Date of Service: 12/04/17
Itemized Statement: Medicaid Amerigroup Star, Dates of Service: 12/04/17 – 12/05/17
Itemized Statements: Accident & Injury, Statement Dates: 04/30/18 - 10/17/19, Dates of Service: 01/30/18
– 04/17/18
Itemized Statement: City of Dallas, Statement Date: 11/12/19, Date of Service: 12/04/17
Itemized Statement: American Radiology Consultants, PLLC, Statement Date: 11/05/19, Dates of Service:
12/05/17
Itemized Statement: Century Integrated Partners, Inc., Statement Date: 10/22/18, Date of Service:
12/04/17
.Joseph
Joseph Klotz
|\|otz
E>:perience/ Awards
Experience/Awards
Chiropraclor-
C/yz'mpmclor — Chiropractic
Cbirobmclz‘: W'e/lne.rs
IY’L/llter: Center-
Center MdGnmy
McKnmgy 2018
2018--C11rrent
Current
Applied
Applied skills
skills and knowledge to t0 effectively
effectively diagnose,
diagnose plan,
plan, and treat
treat complex neurological
neurological
and
and musculoskeletal
musculoskeletal disorders.
disorders.
Clinkal
C/z'zrim/ Director
Directory- Woodlands Medical- Cross
lt’bad/azzdrMedical Cram Roads
Roach 2017-2018
2017~2018
Director
Director of of Physical
Physical Medicine
Medicine and
and Rehabilitation
Rehabihtatjon ,
Applied skills
skills and knowledge to t0 effectively
effectively diagnose, p1 m and treat
diagnose, plan, treat complex neurological
neurological
and musculoskeletal
musculoskeletal disorders
disorders while
while collaborating with Nurse Practitioner.
collaborating with Practitioner.
Developed strong
strong working relationships
relationships with certified family
board certified
With board physicians, nurse
family physicians, nurse
practitioners,
practitioners, and physician
physician assistants
assistants to
to provide exceptional
provide exceptional care
care in
ir1 aa busy
busy outpatient
outpatient
clinical
clinicai setting
setdng
Implemented strong
strong communication skills skills with
With interdisciplinary
interdisciplinary team
team to to optimize
optilnize rehab
rehab
potential
potential
Chief
Chief Chiropractic Clinician — Advanced Spine
Chiropractic Clinician- Spine && Sports
Sports Medicine-
Medicine — Lemmon 2016-2017
Chief
Chief Clinician
Clinicmn
Utilized
Utilized skills
skills and knowledge to t0 effectively
effectively diagnose,
diagnose plan,
plan, and treat
treat complex auto,
auto work,
work and
sport
sport injury
injury cases
cases , ,
Developed strong
strong working relationships
relationships with
with attorneys
attorneys while
while operating
operating under letters
letters of
of
protection
protection
Clinical Director -CORE
Clinical Direclor Pftysical Medidne-
—- CORE waira! Medicine Coppell
-
Coppel/ 2014-2016
2014—2016
Director
Director of of Physical
Physical Medicine and Rehabilitation
Rehabilitation
. Applied
Applied skills
skills and
and knowledge
knowledge to to effectively
effectively diagnose,
diagnose plan,
plan, and treat
treat complex neurological
neurological
and
and musculoskeletal
musculoskeletsl disorders
disorders ,
Developed
Developed strongstrong working relationships
relationships with board certified
certified family
family physicians, nurse
physicians, nurse
practitioners, and
practitioners, physician assistants
and physician assistants toto provide exceptional
provide exceptional care
care in
in a busy outpatient
a busy outpatient
clinical
clinical setting
setting
Implemented
Implemented strongstrong communication skills skills with
With interdisciplinary
interdisciplinary team to t0 optimize
optimize rehab
rehab
potential
potential
Displayed
Displayed exemplary leadership skills
exemplary leadership skills by
by managing additional
addiuonal operational
operational responsibilities,
responsibilitins,
supervising
supervising office
office staff,
staff increasing
increasing productivity,
productivity and en;uring
ensuring procedures were followedfollowed
appropriately
appmpriately ‘
Incteased
Increased clinic profitability by
climc profitability by marketing to to community
community
.America J Tob
Ameritafr C/Jiro radon - 2016
To Chiropractors- 201 6
Conswners Research Council of America
Consumers Research Amenca
Prestigious
Prestigious recognition. _
Being chosen for
for tllis listing is an honor,
this listing is honor and
and my impressive
impressive achievements have placed
placed me
among the
the nations most elite.
elite. _
Dirl'dor
Dim/m o( u/ Ur!ho/Jt•t!i~·
()I/lw.~’mr'/{ and
mid Spine llo/m' 1--lfdlth-
87mm 1--f,J!;I!' I I&I/l/I- Oualitr
0/!(1/171 Cart
Care i\"!m:rim'
J\'://Ir//Ig -a 2014
• Jireparcd
0 Prep. ucd updates ~n patient
updates on patient progress to determine extent
to extent of 0f h~me
home health care
care needs
needs
• Identified
Identified patient discharge needs
patient discharge and assisted
assisted with care
care recommendations
recommendahons
• Provided customized
customlzed home health health care
care to
to patients
patients · .
• Performed, collected,
collected, and administered ordered lab-work 1ab—work and tnedication.
xfiedication.
Director~( PMR—
Diredor 0f PMR- OS]05] Medical
Alcdiml Canter.r
Centaur 2011-201
2011- 2014 +
Director of
0f Physical
Physical Medicine and Rehabilitation
Rehabilitation
Work with and underunder thethe direction
direction and license
license of0f Mayo Clinic
Clinic Fellowship Trained Board
Certified
Certified Orthopedic and Spine
Spine Surgeons while collaborating care
while collaborating care with
with Nurse Practitioners.
Practitioners.
Diagnose,
Diagnose plan,
plan, and treat
treat complex oeuro
neuro and musculoskeletal disorders and collaborate
collaborate with
with
physicians
physicians specializing
specializing in in Vascular Surgery, Primary Care,
Vascular Surgery, Care, Neurology,
Neurology, Pain Management,
Dermatology, Plastic
Plas tic Surgery,
Surgery, and Pediatrics
Pediatrics
Practice evidence based medicine while working and collaborating with the specialistspecialist
Provide both pre and post surgical
surgic- patients
patients with unparalleled healing and wellness
1-1
wellness
Perform all
all health and sport physicals
physicals including physicals
physicals for
for 50 professional
professional athletes
athletes
Perform allall disability
disability assessments for for clients
clients on short and long term disability
disability and
and
impairment ratings for maximum medical
ratings for medical improvement
Occasional venipuncture and other lab lab work
f. 'ictop·
I~
‘
M edim/ Center
'idog Medical Cenler 2011-2014
201 1 —2()1 4
Round on allall post operative patients providing accurate assessments of surgical
surgical wounds,
infections,
infections, lab
lab interpretation, medical chart review and dischar€;1.
dischargg. planning.
Diren‘or qf
Dimtor oz PMR-
PM R - North
NorllJ Texas
Texa: OrthoPedics
Qrt/mgedg‘q qnd
and Spine
Spine 2010-2011
201 0-2011
Director of Physical
Physical Medicine and Rehabilitation
Worked under the direction and license of aa Fellowship Trained Board Certified
Certified Orthopedic
and
and Spine :'urgt:on
surgcon while collaborating with Nurse Practitioners:.
Practitioners;
Diagnosed, planned. and treated complex neuromusculoskeletal
neuromusculoskelctal disorders and provided
complimentary orthopedic therapy and rehabilitation
rehabilitation
Cldrobractic
C/ziragmctic Intem
Intern at M ggdg Health
at Moody Heallé Co1ter
garter 2009
' Diagnosed,
Diagnosed, planned, and treatedtreated musculoskeletal disorders
disorders and provided
provided patients
patients with
customized complimentary phy>ical ph} sicnl medicine, while working ~d1with primary care physicians
physicians to
to
promote
pxomote optimum patient health health ·
Acknowledged
Aclmowledged for for providing excellent
excellent evidenced based physical
physical medicine
Placed
Placed in
1n charge of allall complicated physical
physical therapy
therapy cases
cases ··
Developed gaitgait and balance protocols,
protocols, lligh
high intensity
mtensity strength training
training utilizing
utilizing isometric
Isometric and
plyometric
plyometric exercises,
exercises, and neuromuscular reeducation
reeducau'on techniques,
techniques for cases
cases involvin2:
inv olving
Parkinson's,
Parkinson' s, Cerebral Palsy,
Palsy, and Stoke
Strived
Stn'ved for
for overall
overall patient
padent satisfaction
satisfaction and success
Motivated pat1ents
patients to
to achieve their
their abilities
abilities and goals
Provided paments with vital
Provided patients vital knowledge creating
creating an educational
educational experience
experience that
that did
did not stop
with
with the
the end of treatment
treatment
President of Class-Texas
Prairie”! q( C/axJ-Texai Chiropra<1ic
Cbirqorac'lic Collcg
Cal/cgg 2006-2009
Prepared
Prepared two
two presentations
presentations to
to the
the Board of Regions to t0 help
help make improvements
improvements to to the
the
school
school educationally
educationally and clinically
clinically
Addressed the
the class
class every
every other
other week after
after student body association
student body association meetings
meetings
Organized and assigned
assigned class
class participation.
participation.
Participated m school accreditation
Participated in plan by
accreditation plan by actively
acnveiy working with
with the
the clinical
clinical director
duector and
formed
formed a a council
council to
to help
help improve
unprove theLhe clinical
clinical experience.
experience. · ·
Vice-President
T :ce-Prmdmz o( fmdcw! OJiropractic
of StNdent C/Jtrnpmcz‘z'r: 4ssociatioll
4J10£iat10fl o( LoNi.riana 201)7
0f_LOI/I.rimm 2m)?
Prese~ted
Presented members with with the
thc latest
latest political
pohtical news affecting
affecung the
the profession
profession
Raised
Raised funds to help
funds to help support
support thethe Chiropractic
Chlropractic Association
Association ofof Louisiana
Louisiana by
by organizing
organizing a
a
jambalaya
jambalaya cookout,
cookout, creating
creating SCAL student
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FILED DALLAS COUNTY 1/6/2020 10:51 AM FELICIA PITRE DISTRICT CLERK Treva Parker—Ayodele N0. DC-19-16024 SARAH MARTINEZ § IN THE DISTRICT COURT PLAINTIFF, § § VS. § DALLAS COUNTY, TEXAS § RUDY SANCHEZ § DEFENDANT § 298TH JUDICIAL DISTRICT DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE T0 PLAINTIFF’S REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS Pursuant t0 TeX R. CiV. P. 194, Defendant serves the following First Supplemental Response to Plaintiff s Request for Disclosure and Designation 0f Experts. f. For any testifying expert: 1. The expert’s name, address, and telephone number; 2. The subj ect matter 0n Which the expert will testify; 3. The general substance 0f the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, 01‘ otherwise subject to the control 0f the responding party, documents reflecting such information; 4. Ifthe expert is retained by, employed by, 0r otherwise subject t0 the control 0f the responding party: A. A11 documents, tangible things, reports, models, 0r data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation 0f the expert’s testimony; and B. The expert’s current resume 0r bibliography. Response: Defendant hereby designates and reserves the right t0 call any expert Witness(es) designated by any other party to this case, as well as any experts later designated by any party t0 this case 0n any subject relevant t0 this litigation 0n Which the witness is qualified to testify. In the event that any party to this cause has designated any experts but has been or is subsequently dismissed for any reason or fails t0 callany designated expert at the time 0f trial, Defendant specifically reserves the right to call any such expert previously designated by that party. Defendant further reserves the right t0 withdraw 0r de-designate any expert prior t0 testimony and t0 positively aver that such previously designated expert Will not DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1- be called as a witness at trial and to redesignate same as a consulting expert who Will not be called by any party in this cause. Finally, Defendant reserves the right to supplement this response as additional information concerning experts becomes available. Defendant further hereby designates as adverse expert Witnesses all expert witnesses designated by Plaintiff. Defendant reserves the right to rely upon or to offer, by direct examination or cross-examination, testimony obtained from those experts and rebuttal experts, if any, designated by Plaintiff. By this designation, Defendant does not necessarily agree with, nor vouch for, the credibility of any such Witnesses 0r their opinions, or the reliability, materiality, or admissibility of information and/or tangible things produced by these individuals in general; by this designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit certain opinions and/or evidence from these witnesses t0 the extent that it deems it in its interest t0 d0 s0. Such persons are expected to testify concerning Plaintiffs care and treatment. See Plaintiffs Responses to Defendant’s Request for Disclosure for additional information concerning such health—care providers including medical bills and records relating to Plaintiff. First Supplemental Response: Defendant hereby designates as an expert witness the following individual: Joseph Klotz, DC 7700 Eldorado Pkwy., Suite 100 McKinney, TX 75072 972.540.0608 Dr. Klotz is a chiropractor who has reviewed Sarah Martinez’s medical records and other case materials provided to him, and is expected t0 testify regarding the extent 0fthe injuries sustained by the Plaintiff in the subject motor vehicle accident, the appropriate care and treatment for those injuries, and the fair and reasonable cost of that treatment, both in the past and in the future, if applicable, as set out in the attached report. DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2- Respectfully submitted, ?Mfivfl—g, Chad Kimble, Bar N0. 24007483 State Kyle Smith, State Bar No. 24102512 D. Brent Beasley, State Bar No. 24082669 LAW OFFICE 0F CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANT CERTIFICATE 0F SERVICE The undersigned certifies that on the 6th day 0f January, 2020, a true copy of the foregoing has been served 0n all patties in accordance With Rule 21a, Texas Rules 0f Civil Procedure. 96.1% Brent Beasley DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3- JOSEPH KLOTZ, D.C. 12001 N. CENTRAL EXPRESSWAY DOCTOR 0F CHIROPRACTIC SUITE 800 DALLAS, TX 75243 (214) 750-61 10 FAX — (21 4) 750-5825 December 27, 201 9 Mr. Chad Kimble Low Chad Kimble, P.C. Office of 1204 Sou’rh Whi’re Chapel Blvd. Sou’rhloke, TX 76092 Fox: 81 7-423—7492 RE: Sarah Martinez CLAIM #: 0490698486 DATE OF INJURY: 12/04/1 7 CASE #2 210031 18 Dear Mr. Kimble: | hove had The opporTuniTy ’ro review medical records on Ms. Soroh Martinez. My name is Joseph Klo’rz, DC. om licensed by The s’ro’re of Texas as 0 Chiroprocfor. | hove nine years of | experience Treating pofien’rs as o Chiropractor in The s’ro’re of Texas. hove practiced in The DFW area for seven | years 0nd Son An’ronio for Two years. also hove undergone formal Designo’red Doc’ror Training in The s’ro’re of | Texas 0nd om awaiting To si’r for cerTificoTion ’res’ring for The purpose of evoluo’ring injury cases. In my nine years of experience, | hove Treo’red Thousands of po’rienfs wi’rh complaints of pain in The spine 0nd from ex’rremi’ries mo’ror vehicle accidents or o’rher injuries. | commonly coordinate core wi’rh o’rher specialists ’ro ensure quoli’ry 0nd efficiency of core for The po’rien’r. om experienced wi’rh The cos’rs involved wi’rh | occiden’r cases 0nd ore ossocio’red wi’rh These cases. ’rreo’rmen’rs Tho’r My commen’rs on reasonable 0nd necessary allowances ore based Upon my years of experience in Treating injury potienTs. | regularly coordinate core wi’rh o’rher providers To assure my po’rienTs The quoli’ry core They ge’r con afford. om very familiar wi’rh fee schedules for common TreonenT codes Ground The oreo. Reasonable | 0nd necessary charge recommendo’rions ore based Upon usual 0nd customary fees Ground The region. OVERVIEW The patient is o female Tho’r wos involved in o motor vehicle occiden’r on December O4, 201 7. On January 30, 2018, ’rhe patient presented ’ro Accident & Injury Chiropractic for evoluo’rion 0nd Treatment of mid back pain 0nd low back pain. Range of mo’rion in The Thorocolumbor spine is res’rric’red 0nd posi’rive for pain. Or’rhopedic ’res’ring showed The following posi’rive ’res’rs: SLR [S’rroigh’r Leg Raise]. Neurological Testing is wi’rhin normal limi’rs wi’rh The excep’rion of diminished reflexes symmetrically o’r C5, C6, 0nd L4. Reflexes were no’r performed CIT C7 0nd S1. Streng’rh 0nd sensory ore normal. Clinical impression: Sproin/S’rroin Thoracic, lumbar; Myofosci’ris; Segmental Dysfunc’rion Thoracic, lumbar; Sposm; Pain Thoracic, lumbar; S’riffness of Join’r Thoracic, lumbar. Plan: rehabili’ro’rion. Sarah Martinez December 27, 20] 9 CASE #2 210031 18 Page 2 of 4 OPINION Acciden’r & Iniurv Chiropractic: In reference ’ro ’rhe exam, ’rhe CPT Coding Manual requires Three key components: o de’roiled use of c1 level ||| his’rory, c1 de’roiled exam, 0nd low level of medical decision—moking. In oddi’rion, ’rhe problem severi’ry should c1 be moderate, 0nd physician Time up ’ro Thir’ry minu’res. From The documentation provided, appears This cri’rerio i’r hos been me’r, 0nd ’rhe service is Therefore necessary on January 30, 2018. In reference ’ro ’rhe use of o level re—exom, ’rhe CPT Coding Manual requires ’rwo of ’rhe Three key components: || o problem focused his’rory, o problem focused exam, 0nd s’rroigh’r forward medical decision—moking. In addition, ’rhe problem severity should be seIf-Iimi’red or minor, 0nd physician ’rime o’r Ieos’r ’ren minu’res. Based on my clinical experience wi’rh sof’r Tissue relo’red injuries, re—exomino’rion is worron’red every six visi’rs ’ro determine confinued need of core vs medical discharge. From ’rhe documen’ro’rion provided, appears ’rhis criteria hos no’r been me’r, i’r 0nd ’rhe level re—exom was therefore no’r reasonable 0nd no’r medically necessary on February 01, 2018, cs o || new po’rienT level exominofion wos performed The previous visiT. From The documen’ro’rion provided This service ||| did mee’r The following requirements 0nd was therefore reasonable 0nd necessary on March 20, 201 8. In reference ’ro The use of o level re—exom, The CPT Coding Manual requires Three key componenTs: o deToiled ||| hisTory,o deToiled exam, 0nd o modero’re level of medical decision—moking. In addition, The problem severi’ry should be modero’re, 0nd physician Time 0T Ieos’r Thir’ry minutes. Based on my clinical experience wi’rh sof’r Tissue relo’red injuries, re—exomino’rion is worron’red every six visi’rs ’ro determine continued need of core vs medical discharge. From The documentation provided, appears This cri’rerio hos been me’r, 0nd The level i’r re—exom was ||| therefore reasonable 0nd necessary on February 19, 2018. From The documentation provided, The following requirements were no’r me’r 0nd ’rhe following dates of service were bo’rh no’r reasonable 0nd no’r medically necessary on March 21 201 8, os o level examination was performed one day before. Additionally, The following , || do’re of service did no’r mee’r ’rhe requirements, April 17, 2018, Gs ’rhe po’rien’r should hove already been discharged o’r ’rhis poin’r. In reference The chiropractic adjustment, from my experience wi’rh The diagnosis of This po’rien’r, o Trial period ’ro of Treo’rmen’r consisting 2—3 weeks hos been indicated ’ro provide 0n adequo’re sample of ’rhe success of ’rhe ’rreo’rmen’r. If The chiroproc’ror con demons’rro’re objec’rive functional improvement during The Trial period, Then up ’ro 18—22 Treo’rmen’rs over o period of six weeks is recommended. In ’rhis case, There was objecTive func’rionol improvemenf during The Trial period of core. Therefore, ’rhe Ios’r do’re of service should hove been March 13, 20] 8, 0nd no’r April 12, 2018. In reference To The use of Theropeufic exercises, based on my clinical experience wi’rh sof’r Tissue relo’red injuries, | recommend up ’ro Ten sessions over on eighT—week period. The proc’ri’rioner should allow for fading of Treo’rmenT frequency from Three visi’rs perweek To one or less, wi’rh on emphasis on oc’rive seIf—direc’red home PT. If objec’rive functional improvemen’r during The firs’r ’ren sessions is documented, Then recommend up ’ro eigh’r more sessions. | In This case, There wos objective functional improvement during The ’rriol period of core. Therefore, The IosT doTe of service should hove been April 05, 2018, 0nd no’r April 12, 2018. From myexperience wi’rh ’rhe fee schedules Ground ’rhe DFW oreo, ’rhe charges for ’rhe services below were excessive. The below shows ’rhe omoun’r billed for each service 0nd c1 range of ’rhe reasonable charges for Iis’r each: Billed U&C Range Level ||| Exam $325.00 $1 00.00 - $1 60.00 X 1 Level || Re—Exom $1 60.00 $70.00 - $100.00 X 1 Level ||| Re—Exom $204.00 $80.00 - $1 20.00 X 1 CMT 1—2 $96.00 $50.00 — $70.00 X 17 CMT 3—4 $1 06.00 $65.00 — $85.00 X 1 Therapeutic Exercises $98/uni’r $40.00 - $60.00/uni’r x 18 Sarah Martinez December 27, 20] 9 CASE #2 210031 18 Page 3 of 4 The ’ro’rol reasonable charges for ’rhe necessary Treatment including imaging ore between $1 ,885 0nd $2,735. Based Upon my review of ’rhe cloimon’r’s medical record, is my opinion wi’rhin o reasonable degree of i’r medical probability along wi’rh my experience, Training, education 0nd knowledge in Treating po’rien’rs wi’rh similar complaints Gs This cloimon’r, Tho’r ’rhe patient will no’r require any fu’rure medical Treo’rmen’r for The injuries sus’roined by The individual in The mo’ror vehicle accident. Thank you for The opportunity ’ro review The medical records on Ms. Sarah Morfinez. Dic’ro’red, reviewed, opinion verified, 0nd o’r’res’red ’ro by my original signo’rure. Sincerely, /// Joseph Klo’rz, D.C. Doc’ror of Chiroproc’ric 1 1470 JK/ck/pl The opinions rendered in ’rhis case ore ’rhe opinions of ’rhe evoluo’ror. This review hos been conduc’red on ’rhe basis of ’rhe medical records provided, wi’rh ’rhe assumption Tho’r ’rhe material is ’rrue 0nd correct. If more information becomes available 0T a Io’rer do’re, on additional service/repor’r/reconsidero’rion may be requested. Sarah Martinez December 27, 2019 CASE #: 21003118 Page 4 of 4 SUMMARY OF RECORDS Dallas Fire-Rescue: 12/04/17 Baylor University Medical Center ED: Wendy Wong, M.D./Ali Farzad, M.D., 12/04/17 - 02/05/17 (Chiropractic Evaluation & Treatment, un-documented facility/provider name illegible): 01/30/18, 02/01/18, 02/02/18, 02/05/18, 02/06/18, 02/08/18, 02/09/18, 02/10/18, 02/13/18, 02/14/18, 02/19/18, 02/21/19, 02/23/18, 02/26/18, 02/27/18, 02/28/19, 03/05/18, 03/06/18, 03/09/18, 03/12/18, -3/13/18, 03/20/18, 03/21/18, 03/23/18, 03/26/18, 03/27/18, 03/28/18, 04/09/18, 04/11/18, 04/12/18 (Accident & Injury Chiropractic), patient participated in chiropractic therapy 02/01/18 – 04/25/18), undocumented provider – 04/25/18 Musculoskeletal Exam (undocumented facility): 03/01/18, 04/17/18 RolleLaw, To: 29th District Court, George L. Allen, Sr., Courts Building: 12/12/19 Affidavit of Medical Charges from Baylor University Medical Center: 11/06/19 Affidavit of Medical Records from Baylor University Medical Center: 06/05/18, Medical Records Affidavit, Baylor University Medical Center, Dates of Service: 06/05/18 Affidavit of Necessity of Services/Reasonableness of Charges, Accident & Injury Chiropractic: 10/21/19 Affidavit of Medical Records, Accident & Injury; Affidavit for Authorization of Business Records: 10/21/19 Black & White copy Texas Under 21 Driver License: (name illegible) Affidavit of Medical Charges from City of Dallas EMS/Affidavit of Medical Expense: 11/15/19 Affidavit of Medical Charges from American Radiology Consultants: (undated) MSN Affidavit for American Radiology Consultants: 11/05/19 Affidavit of Medical Charges from Century Integrated Partners, Filed: 12/12/19 Affidavit of Medical Charges, Century Integrated Partners: 10/25/19 Affidavit of Necessity of Services/Reasonableness of Charges, Accident & Injury Chiropractic: 10/21/19 Affidavit for Authentication of Business Records, Accident & Injury Chiropractic: 10/21/19 Affidavit of Medical Expenses, City of Dallas EMS: 11/15/19 MSN Affidavit for (billing records), American Radiology Consultants: 11/05/19 Affidavit of Medical Charges, Century Integrated Partners: 10/25/19 Itemized Statement: Baylor University Medical Center, Date of Service: 12/04/17 Itemized Statement: Medicaid Amerigroup Star, Dates of Service: 12/04/17 – 12/05/17 Itemized Statements: Accident & Injury, Statement Dates: 04/30/18 - 10/17/19, Dates of Service: 01/30/18 – 04/17/18 Itemized Statement: City of Dallas, Statement Date: 11/12/19, Date of Service: 12/04/17 Itemized Statement: American Radiology Consultants, PLLC, Statement Date: 11/05/19, Dates of Service: 12/05/17 Itemized Statement: Century Integrated Partners, Inc., Statement Date: 10/22/18, Date of Service: 12/04/17 .Joseph Joseph Klotz |\|otz E>:perience/ Awards Experience/Awards Chiropraclor- C/yz'mpmclor — Chiropractic Cbirobmclz‘: W'e/lne.rs IY’L/llter: Center- Center MdGnmy McKnmgy 2018 2018--C11rrent Current Applied Applied skills skills and knowledge to t0 effectively effectively diagnose, diagnose plan, plan, and treat treat complex neurological neurological and and musculoskeletal musculoskeletal disorders. disorders. Clinkal C/z'zrim/ Director Directory- Woodlands Medical- Cross lt’bad/azzdrMedical Cram Roads Roach 2017-2018 2017~2018 Director Director of of Physical Physical Medicine Medicine and and Rehabilitation Rehabihtatjon , Applied skills skills and knowledge to t0 effectively effectively diagnose, p1 m and treat diagnose, plan, treat complex neurological neurological and musculoskeletal musculoskeletal disorders disorders while while collaborating with Nurse Practitioner. collaborating with Practitioner. Developed strong strong working relationships relationships with certified family board certified With board physicians, nurse family physicians, nurse practitioners, practitioners, and physician physician assistants assistants to to provide exceptional provide exceptional care care in ir1 aa busy busy outpatient outpatient clinical clinicai setting setdng Implemented strong strong communication skills skills with With interdisciplinary interdisciplinary team team to to optimize optilnize rehab rehab potential potential Chief Chief Chiropractic Clinician — Advanced Spine Chiropractic Clinician- Spine && Sports Sports Medicine- Medicine — Lemmon 2016-2017 Chief Chief Clinician Clinicmn Utilized Utilized skills skills and knowledge to t0 effectively effectively diagnose, diagnose plan, plan, and treat treat complex auto, auto work, work and sport sport injury injury cases cases , , Developed strong strong working relationships relationships with with attorneys attorneys while while operating operating under letters letters of of protection protection Clinical Director -CORE Clinical Direclor Pftysical Medidne- —- CORE waira! Medicine Coppell - Coppel/ 2014-2016 2014—2016 Director Director of of Physical Physical Medicine and Rehabilitation Rehabilitation . Applied Applied skills skills and and knowledge knowledge to to effectively effectively diagnose, diagnose plan, plan, and treat treat complex neurological neurological and and musculoskeletal musculoskeletsl disorders disorders , Developed Developed strongstrong working relationships relationships with board certified certified family family physicians, nurse physicians, nurse practitioners, and practitioners, physician assistants and physician assistants toto provide exceptional provide exceptional care care in in a busy outpatient a busy outpatient clinical clinical setting setting Implemented Implemented strongstrong communication skills skills with With interdisciplinary interdisciplinary team to t0 optimize optimize rehab rehab potential potential Displayed Displayed exemplary leadership skills exemplary leadership skills by by managing additional addiuonal operational operational responsibilities, responsibilitins, supervising supervising office office staff, staff increasing increasing productivity, productivity and en;uring ensuring procedures were followedfollowed appropriately appmpriately ‘ Incteased Increased clinic profitability by climc profitability by marketing to to community community .America J Tob Ameritafr C/Jiro radon - 2016 To Chiropractors- 201 6 Conswners Research Council of America Consumers Research Amenca Prestigious Prestigious recognition. _ Being chosen for for tllis listing is an honor, this listing is honor and and my impressive impressive achievements have placed placed me among the the nations most elite. elite. _ Dirl'dor Dim/m o( u/ Ur!ho/Jt•t!i~· ()I/lw.~’mr'/{ and mid Spine llo/m' 1--lfdlth- 87mm 1--f,J!;I!' I I&I/l/I- Oualitr 0/!(1/171 Cart Care i\"!m:rim' J\'://Ir//Ig -a 2014 • Jireparcd 0 Prep. ucd updates ~n patient updates on patient progress to determine extent to extent of 0f h~me home health care care needs needs • Identified Identified patient discharge needs patient discharge and assisted assisted with care care recommendations recommendahons • Provided customized customlzed home health health care care to to patients patients · . • Performed, collected, collected, and administered ordered lab-work 1ab—work and tnedication. xfiedication. Director~( PMR— Diredor 0f PMR- OS]05] Medical Alcdiml Canter.r Centaur 2011-201 2011- 2014 + Director of 0f Physical Physical Medicine and Rehabilitation Rehabilitation Work with and underunder thethe direction direction and license license of0f Mayo Clinic Clinic Fellowship Trained Board Certified Certified Orthopedic and Spine Spine Surgeons while collaborating care while collaborating care with with Nurse Practitioners. Practitioners. Diagnose, Diagnose plan, plan, and treat treat complex oeuro neuro and musculoskeletal disorders and collaborate collaborate with with physicians physicians specializing specializing in in Vascular Surgery, Primary Care, Vascular Surgery, Care, Neurology, Neurology, Pain Management, Dermatology, Plastic Plas tic Surgery, Surgery, and Pediatrics Pediatrics Practice evidence based medicine while working and collaborating with the specialistspecialist Provide both pre and post surgical surgic- patients patients with unparalleled healing and wellness 1-1 wellness Perform all all health and sport physicals physicals including physicals physicals for for 50 professional professional athletes athletes Perform allall disability disability assessments for for clients clients on short and long term disability disability and and impairment ratings for maximum medical ratings for medical improvement Occasional venipuncture and other lab lab work f. 'ictop· I~ ‘ M edim/ Center 'idog Medical Cenler 2011-2014 201 1 —2()1 4 Round on allall post operative patients providing accurate assessments of surgical surgical wounds, infections, infections, lab lab interpretation, medical chart review and dischar€;1. dischargg. planning. Diren‘or qf Dimtor oz PMR- PM R - North NorllJ Texas Texa: OrthoPedics Qrt/mgedg‘q qnd and Spine Spine 2010-2011 201 0-2011 Director of Physical Physical Medicine and Rehabilitation Worked under the direction and license of aa Fellowship Trained Board Certified Certified Orthopedic and and Spine :'urgt:on surgcon while collaborating with Nurse Practitioners:. Practitioners; Diagnosed, planned. and treated complex neuromusculoskeletal neuromusculoskelctal disorders and provided complimentary orthopedic therapy and rehabilitation rehabilitation Cldrobractic C/ziragmctic Intem Intern at M ggdg Health at Moody Heallé Co1ter garter 2009 ' Diagnosed, Diagnosed, planned, and treatedtreated musculoskeletal disorders disorders and provided provided patients patients with customized complimentary phy>ical ph} sicnl medicine, while working ~d1with primary care physicians physicians to to promote pxomote optimum patient health health · Acknowledged Aclmowledged for for providing excellent excellent evidenced based physical physical medicine Placed Placed in 1n charge of allall complicated physical physical therapy therapy cases cases ·· Developed gaitgait and balance protocols, protocols, lligh high intensity mtensity strength training training utilizing utilizing isometric Isometric and plyometric plyometric exercises, exercises, and neuromuscular reeducation reeducau'on techniques, techniques for cases cases involvin2: inv olving Parkinson's, Parkinson' s, Cerebral Palsy, Palsy, and Stoke Strived Stn'ved for for overall overall patient padent satisfaction satisfaction and success Motivated pat1ents patients to to achieve their their abilities abilities and goals Provided paments with vital Provided patients vital knowledge creating creating an educational educational experience experience that that did did not stop with with the the end of treatment treatment President of Class-Texas Prairie”! q( C/axJ-Texai Chiropra<1ic Cbirqorac'lic Collcg Cal/cgg 2006-2009 Prepared Prepared two two presentations presentations to to the the Board of Regions to t0 help help make improvements improvements to to the the school school educationally educationally and clinically clinically Addressed the the class class every every other other week after after student body association student body association meetings meetings Organized and assigned assigned class class participation. participation. Participated m school accreditation Participated in plan by accreditation plan by actively acnveiy working with with the the clinical clinical director duector and formed formed a a council council to to help help improve unprove theLhe clinical clinical experience. experience. · · Vice-President T :ce-Prmdmz o( fmdcw! OJiropractic of StNdent C/Jtrnpmcz‘z'r: 4ssociatioll 4J10£iat10fl o( LoNi.riana 201)7 0f_LOI/I.rimm 2m)? Prese~ted Presented members with with the thc latest latest political pohtical news affecting affecung the the profession profession Raised Raised funds to help funds to help support support thethe Chiropractic Chlropractic Association Association ofof Louisiana Louisiana by by organizing organizing a a jambalaya jambalaya cookout, cookout, creating creating SCAL student