On April 26, 2019 a
Party Statement
was filed
involving a dispute between
Rodriguez, Matilde,
and
Almond, James R.,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
DALLAS COUNTY
11/7/2019 4:24 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-1 9-05985
MATILDE RODRIGUEZ, IN THE DISTRICT COURT
Plaintiff,
V. 191ST JUDICIAL DISTRICT
JAMES ALMOND,
Defendant. DALLAS COUNTY, TEXAS
COST OF SERVICES AFFIDAVIT OF LONE STAR RADIOLOGY
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff Matilde Guadalupe Gloria Rodriguez files the attached Cost of
Services Affidavit of Lone Star Radiology in accordance with section 18.001, et seq. of
the Texas Civil Practices & Remedies Code.
Respectfully submitted,
/s/ Mahtab Doty
Mahtab (Mattie) Doty
State Bar No. 24105031
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(81 7) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document was
served on all counsel of record and/or pro se parties in accordance with Rules 21 and
21 a of the Texas Rules of Civil Procedure on this 7t“ day of November, 201 9.
/s/ Mahtab Doty
Mahtab (Mattie) Doty
663T 6F SERVICES AFFIDAVIT 6F L6NE §TAR RADIGLGGY Page 4
)
)
)
Plaintiff. ) IN THE DISTRICT IN AND FOR COUNTY,
) TEXAS
vs. )
)
)
)
Defendant )
AFFIDAVIT OF NECESSITY 0F SERVICES/REASONABLENESS OF CHARGES
Before me, the undersigned authority, on this day personally appeared DR. LOU
SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making
this affidavit, and personally acquainted with the facts herein stated:
10
I am the custodian of billing records for LONE STAR RADIOLOGY. Attached
hereto are billing records from 03/05/2019, pertaining to MATILDE GLORIA,
ll DOB: 03/14/1978, SSN: N/A. These pages of billing records are kept by LONE
STAR RADIOLOGY, in the regular course of business, and it was the regular
12 course of business of LONE STAR RADIOLOGY, for an employee or representative
of LONE STAR RADIOLOGY, with knowledge of the act, event, condition, opinion,
l3 or diagnoses recorded to make the record or to transmit information thereof
to be included in such record and the record was made at or near the time or
reasonably after the time that the service was provided.
l4
The total cost of services for MATILDE GLORIA received at this facility is
15 $346.00 (which may include a Records Summary Report fee of $150.00). The
total amount adjusted, payments, and write off is $0.00. The adjusted total
l6 cost reflects billing and adjustment as of the date of this affidavit. With
the sole exception of fees related to the Records Summary Report fee of
l7 $150.00, these services and charges were both reasonable and necessary in
connection with MATILDE GLORIA treatment. The amount currently unpaid but
which LONE STAR RADIOLOGY has a right to be paid after any adjustments or
18
credits is $346.00.
l9 I am familiar with the charges rendered in the vicinity in which they were
incurred. I consider these charges to be reasonable and customary for all
20 like or similar services. The records attached hereto are the original
exact duplicates of the original.
21
22
Affiant
SWORN To AND SUBSCRIBED before me on the /r) day of Qfo&h(ibgjayfia , 2019.
23 ”
a
,
I4 I.
g
24 Notary Pfiblic, State of Texas
Notary’s printed name and
25 commission expires:05-13-2023
LWYSAUNAS
My Notary ID # 130225380
Expires May 13, 2023
Document Filed Date
November 07, 2019
Case Filing Date
April 26, 2019
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED DALLAS COUNTY 11/7/2019 4:24 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-1 9-05985 MATILDE RODRIGUEZ, IN THE DISTRICT COURT Plaintiff, V. 191ST JUDICIAL DISTRICT JAMES ALMOND, Defendant. DALLAS COUNTY, TEXAS COST OF SERVICES AFFIDAVIT OF LONE STAR RADIOLOGY TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff Matilde Guadalupe Gloria Rodriguez files the attached Cost of Services Affidavit of Lone Star Radiology in accordance with section 18.001, et seq. of the Texas Civil Practices & Remedies Code. Respectfully submitted, /s/ Mahtab Doty Mahtab (Mattie) Doty State Bar No. 24105031 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (81 7) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document was served on all counsel of record and/or pro se parties in accordance with Rules 21 and 21 a of the Texas Rules of Civil Procedure on this 7t“ day of November, 201 9. /s/ Mahtab Doty Mahtab (Mattie) Doty 663T 6F SERVICES AFFIDAVIT 6F L6NE §TAR RADIGLGGY Page 4 ) ) ) Plaintiff. ) IN THE DISTRICT IN AND FOR COUNTY, ) TEXAS vs. ) ) ) ) Defendant ) AFFIDAVIT OF NECESSITY 0F SERVICES/REASONABLENESS OF CHARGES Before me, the undersigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: 10 I am the custodian of billing records for LONE STAR RADIOLOGY. Attached hereto are billing records from 03/05/2019, pertaining to MATILDE GLORIA, ll DOB: 03/14/1978, SSN: N/A. These pages of billing records are kept by LONE STAR RADIOLOGY, in the regular course of business, and it was the regular 12 course of business of LONE STAR RADIOLOGY, for an employee or representative of LONE STAR RADIOLOGY, with knowledge of the act, event, condition, opinion, l3 or diagnoses recorded to make the record or to transmit information thereof to be included in such record and the record was made at or near the time or reasonably after the time that the service was provided. l4 The total cost of services for MATILDE GLORIA received at this facility is 15 $346.00 (which may include a Records Summary Report fee of $150.00). The total amount adjusted, payments, and write off is $0.00. The adjusted total l6 cost reflects billing and adjustment as of the date of this affidavit. With the sole exception of fees related to the Records Summary Report fee of l7 $150.00, these services and charges were both reasonable and necessary in connection with MATILDE GLORIA treatment. The amount currently unpaid but which LONE STAR RADIOLOGY has a right to be paid after any adjustments or 18 credits is $346.00. l9 I am familiar with the charges rendered in the vicinity in which they were incurred. I consider these charges to be reasonable and customary for all 20 like or similar services. The records attached hereto are the original exact duplicates of the original. 21 22 Affiant SWORN To AND SUBSCRIBED before me on the /r) day of Qfo&h(ibgjayfia , 2019. 23 ” a , I4 I. g 24 Notary Pfiblic, State of Texas Notary’s printed name and 25 commission expires:05-13-2023 LWYSAUNAS My Notary ID # 130225380 Expires May 13, 2023