On March 22, 2023 a
Party Notice
was filed
involving a dispute between
Munguia, Manuel,
and
Shannon, Frances,
for Motor Vehicle Accident - Over $250,000
in the District Court of Montgomery County.
Preview
CAUSE NO. 23-05-07428
MANUEL MUNGUIA § IN THE DISTRICT COURT
Plaintiff, §
§
v. § 457 JUDICIAL DISTRICT
FRANCES SHANNON
Defendant. § MONTGOMERYCOUNTY, TEXAS
PLAINTIFF’SNOT FILING IDAVI TS
CERNING COST & NECESSITY OF SERVICES
TO: Defendant FRANCES SHANNON, by and through her attorney of record Jason A.
Powers with Lewis Brisbois Bisgaard & Smith LLP at 24 Greenway Plaza, Suite 1
Houston, Texas 77046.
Plaintiff, MANUEL MUNGUIA s this Notice of Service of Affidavits, Declarations,
and Original Medical and/or Billing Records pursuant to Rule 902(10) of the Texas Rules of
Civil Evidence and Section 18.001 of the Texas Civil Prac ices & Remedies Code and
respectfully shows the Court the following:
Plaintiff serves to all counsel of record the following Affidavits and Declarations of the
custodian of records and original medical and/or billing records of the following health car
providers:
MED AFF Townsen Memorial Hospital Imaging - Humble records
MED AFF Townsen Memorial Hospital Imaging - Humble billing
The above mentioned Affidavits, Declarations and original medical and/or billing records
are sought to be used as evidence in this cause. The Affidavits and Declarations idetify and
ame the person who provided the services or the person in charge of records showing the
services provided and the charges made.
[1]
The pleading is filed pursuant to Section 18.001 of the Texas Civil Practice and
Remedies Code, and the produced bill ffidavits and Declarations show that the amount
charged for services were reasonable at the time and place that the service was provided and that
the service was necessary, and this is sufficient evidence to support a finding of fact by judge or
jury hat the amount charges was reasonable ohat the service was necessary unless
controverting affidavits are filed. This pleading shall serve as a proper notice to all parties.
Resp ully submi ed,
uynh
ARAH Y NHI HUYNH
SBN : 24092558
shuynh@thehuynhlawfirm.com
PAV “PA SAVINOV
: 24086698
inov@thehunhla m.com
MICHAEL
m.c
orp e, S
Houston, TX 77036
Tel. : (281) 702
Fax : (281) 7
mail : eservice@thehuynhlawf rm.c
S FOR PLAI
CERTIFICATE OF SERVICE
thi en served up
arties of record by electronic mail, facsimile, first ertified ail, July
pursuant ents o Rul
VÃa ervice:Jason Powers@lewisbrisbois.com
Jason A. Powers
AndrewJ. Gammill
Lewis Brisbois Bisgaard & Smith LLP
24 Greenway Plaza, Suite 1400
Houston, Texas 77046
/S/ SARAH HUYNH
Sarah Huynh
Document Filed Date
July 28, 2023
Case Filing Date
March 22, 2023
Category
Motor Vehicle Accident - Over $250,000
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CAUSE NO. 23-05-07428 MANUEL MUNGUIA § IN THE DISTRICT COURT Plaintiff, § § v. § 457 JUDICIAL DISTRICT FRANCES SHANNON Defendant. § MONTGOMERYCOUNTY, TEXAS PLAINTIFF’SNOT FILING IDAVI TS CERNING COST & NECESSITY OF SERVICES TO: Defendant FRANCES SHANNON, by and through her attorney of record Jason A. Powers with Lewis Brisbois Bisgaard & Smith LLP at 24 Greenway Plaza, Suite 1 Houston, Texas 77046. Plaintiff, MANUEL MUNGUIA s this Notice of Service of Affidavits, Declarations, and Original Medical and/or Billing Records pursuant to Rule 902(10) of the Texas Rules of Civil Evidence and Section 18.001 of the Texas Civil Prac ices & Remedies Code and respectfully shows the Court the following: Plaintiff serves to all counsel of record the following Affidavits and Declarations of the custodian of records and original medical and/or billing records of the following health car providers: MED AFF Townsen Memorial Hospital Imaging - Humble records MED AFF Townsen Memorial Hospital Imaging - Humble billing The above mentioned Affidavits, Declarations and original medical and/or billing records are sought to be used as evidence in this cause. The Affidavits and Declarations idetify and ame the person who provided the services or the person in charge of records showing the services provided and the charges made. [1] The pleading is filed pursuant to Section 18.001 of the Texas Civil Practice and Remedies Code, and the produced bill ffidavits and Declarations show that the amount charged for services were reasonable at the time and place that the service was provided and that the service was necessary, and this is sufficient evidence to support a finding of fact by judge or jury hat the amount charges was reasonable ohat the service was necessary unless controverting affidavits are filed. This pleading shall serve as a proper notice to all parties. Resp ully submi ed, uynh ARAH Y NHI HUYNH SBN : 24092558 shuynh@thehuynhlawfirm.com PAV “PA SAVINOV : 24086698 inov@thehunhla m.com MICHAEL m.c orp e, S Houston, TX 77036 Tel. : (281) 702 Fax : (281) 7 mail : eservice@thehuynhlawf rm.c S FOR PLAI CERTIFICATE OF SERVICE thi en served up arties of record by electronic mail, facsimile, first ertified ail, July pursuant ents o Rul VÃa ervice:Jason Powers@lewisbrisbois.com Jason A. Powers AndrewJ. Gammill Lewis Brisbois Bisgaard & Smith LLP 24 Greenway Plaza, Suite 1400 Houston, Texas 77046 /S/ SARAH HUYNH Sarah Huynh