Preview
Filed: 1/9/2019 8:09 AM
J OHND. KINARD - District Clerk
Galveston County, Texas
Envelope No. 30224902
No. 17-CV-1561 By: Shailja Dixit
1/9/2019 8:51 AM
PAOLA MEDEL IN THE DISTRICT COURT OF
vs. GALVESTON COUNTY, TEXAS
NICHOLAS HOLBROOK 122ND JUDICIAL DISTRICT
NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff by and through their attorney(s) of record: John Papapavlou
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written
questions will be taken of Custodian of Records for:
(39) Texas Eye Institute (Attn: Medical Records) (Medical)
11914 Astoria Boulevard, Suite 680, Houston, TX 77089
before a Notary Public for TEAM LEGAL
13100 Wortham Center Dr., Suite 140, Houston, Texas 77065
713-937-4242, Fax 713-937-9995, www.teamlegal.net
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 Rule
200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be
erved on the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such
record in the possession, custody or control of the said witness, and every such record to which the witness may have access
pertaining to: Paola Emperatriz Medel a/k/a Ramon; Amaro
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.
TEAM LEGAL
Wide 6 Ud Lbs lI
Wade B. Williams
Lewis & Williams
1014 Hercules Avenue
G EAA
Houston, TX 77058
281-652-5509 Fax 281-652-5517
Attorney for Defendant
The Leader in Litigation Support SBA # 21582900
I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel of Record by hand
sted, on this day.
delivery, fax, email, commercial delivery service, and/or certified mail, return recgipt req
Dated: January 3, 2019 by. J ——
Order No. 23620
No. 17-CV-1561
PAOLA MEDEL IN THE DISTRICT COURT OF
vs. GALVESTON COUNTY, TEXAS
NICHOLAS HOLBROOK 122ND JUDICIAL DISTRICT
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: Texas Eye Institute (Attn: Medical Records)
Records Pertaining To: Paola Emperatriz Medel a/k/a Ramon; Amaro
Type of Records: any and all medical records (on paper and/or in electronic format), including but not limited to, all
treatment records, reports, notes, tests and results, patient demographics and/or face sheets, patient
registration form(s), patient history, sign-in sheets, consents, insurance information, questionnaires,
correspondence, records contained in the file from other sources, and all related documents
Please state your full name.
Answer:
Please state by whom you are employed and the business address.
Answer:
What is the title of your position or job?
Answer:
Are the medical records, outlined in the subpoena duces tecum, pertaining to the above-named person, in your custody or
subject to your control, supervision or direction?
Answer:
Are you able to identify these medical records as the originals or true copies of the originals?
Answer:
Please hand to the Notary Public taking this written deposition copies of the records requested in the subpoena duces tecum.
Have you done as requested? If not, why?
Answer:
Are the copies which you have handed to the Notary Public taking this written deposition true and correct copies of all such
medical records?
Answer:
Order No. 23620.039 Team Legal
Were such medical records kept in the regular course of business of this facility?
Answer:
Please state whether or not it was the regular course of business of the above mentioned facility for a person with knowledge
of the acts, events, conditions, opinion, or diagnoses, recorded to make the record or to transmit information thereof to be
included in such record.
Answer:
10. Were the medical records made by nurses, doctors and other employees or representatives made at or near the time when the
acts, events, conditions, courses of treatment, diagnoses and other information contained therein occurred, were observed or
rendered, or made reasonably soon thereafter?
Answer:
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared >
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
My Commission Expires:
TEAM LEGAL
d
The Leader in
A
= nN
Litigati on. Support
Order No. 23620.039 Team Legal
Preview
Filed: 1/9/2019 8:09 AM J OHND. KINARD - District Clerk Galveston County, Texas Envelope No. 30224902 No. 17-CV-1561 By: Shailja Dixit 1/9/2019 8:51 AM PAOLA MEDEL IN THE DISTRICT COURT OF vs. GALVESTON COUNTY, TEXAS NICHOLAS HOLBROOK 122ND JUDICIAL DISTRICT NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff by and through their attorney(s) of record: John Papapavlou You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records for: (39) Texas Eye Institute (Attn: Medical Records) (Medical) 11914 Astoria Boulevard, Suite 680, Houston, TX 77089 before a Notary Public for TEAM LEGAL 13100 Wortham Center Dr., Suite 140, Houston, Texas 77065 713-937-4242, Fax 713-937-9995, www.teamlegal.net 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 Rule 200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be erved on the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such record in the possession, custody or control of the said witness, and every such record to which the witness may have access pertaining to: Paola Emperatriz Medel a/k/a Ramon; Amaro 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. TEAM LEGAL Wide 6 Ud Lbs lI Wade B. Williams Lewis & Williams 1014 Hercules Avenue G EAA Houston, TX 77058 281-652-5509 Fax 281-652-5517 Attorney for Defendant The Leader in Litigation Support SBA # 21582900 I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel of Record by hand sted, on this day. delivery, fax, email, commercial delivery service, and/or certified mail, return recgipt req Dated: January 3, 2019 by. J —— Order No. 23620 No. 17-CV-1561 PAOLA MEDEL IN THE DISTRICT COURT OF vs. GALVESTON COUNTY, TEXAS NICHOLAS HOLBROOK 122ND JUDICIAL DISTRICT DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: Texas Eye Institute (Attn: Medical Records) Records Pertaining To: Paola Emperatriz Medel a/k/a Ramon; Amaro Type of Records: any and all medical records (on paper and/or in electronic format), including but not limited to, all treatment records, reports, notes, tests and results, patient demographics and/or face sheets, patient registration form(s), patient history, sign-in sheets, consents, insurance information, questionnaires, correspondence, records contained in the file from other sources, and all related documents Please state your full name. Answer: Please state by whom you are employed and the business address. Answer: What is the title of your position or job? Answer: Are the medical records, outlined in the subpoena duces tecum, pertaining to the above-named person, in your custody or subject to your control, supervision or direction? Answer: Are you able to identify these medical records as the originals or true copies of the originals? Answer: Please hand to the Notary Public taking this written deposition copies of the records requested in the subpoena duces tecum. Have you done as requested? If not, why? Answer: Are the copies which you have handed to the Notary Public taking this written deposition true and correct copies of all such medical records? Answer: Order No. 23620.039 Team Legal Were such medical records kept in the regular course of business of this facility? Answer: Please state whether or not it was the regular course of business of the above mentioned facility for a person with knowledge of the acts, events, conditions, opinion, or diagnoses, recorded to make the record or to transmit information thereof to be included in such record. Answer: 10. Were the medical records made by nurses, doctors and other employees or representatives made at or near the time when the acts, events, conditions, courses of treatment, diagnoses and other information contained therein occurred, were observed or rendered, or made reasonably soon thereafter? Answer: WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared > 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 My Commission Expires: TEAM LEGAL d The Leader in A = nN Litigati on. Support Order No. 23620.039 Team Legal