Preview
FILED
8/31/2020 3:51 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Veronica Vaughn DEPUTY
N0. DC-19-01170
CARLOS VEGA § IN THE DISTRICT COURT
PLAINTIFF, §
§
VS. § DALLAS COUNTY, TEXAS
§
JOSEFINA VASQUEZ §
DEFENDANT. § 298TH JUDICIAL DISTRICT
DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION 0F EXPERTS
Pursuant t0 TeX R. Civ. P. 194, Defendant serves the following First Supplemental
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 0f the basis for them, 0r if the expert is not retained by, employed by, 0r
otherwise subject t0 the control of the responding party, documents reflecting such
information;
4. Ifthe expert is retained by, employed by, or otherwise subject t0 the control
0f the responding party:
A. A11 documents, tangible
things, reports, models, 0r data
compilations that have been provided reviewed by, 0r prepared by or for the
t0,
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 to call any expert Witness(es)
designated by any other party t0 this case, as well as any experts later designated
by any party to this case on any subject relevant to this litigation on which the
Witness is qualified t0 testify. In the event that any party t0 this cause has
designated any experts but has been 0r is subsequently dismissed for any reason 0r
fails to call any designated expert at the time of trial, Defendant specifically
reserves the right t0 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 to positively aver that such previously designated expert will not
be called as a Witness at trial and t0 redesignate same as a consulting expert who
will not be called by any party in this cause. Finally, Defendant reserves the right
DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION OF EXPERTS -1-
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 0r 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 0f any
such Witnesses 0r their opinions, or the reliability, materiality, 0r admissibility 0f
information and/or tangible things produced by these individuals in general; by this
designation Defendant is simply reserving the opportunity t0 rely upon or elicit
certain opinions and/or evidence from these Witnesses t0 the extent that it deems it
in its interest t0 do so.
Such persons are expected t0 testify concerning Plaintiff’ s care and treatment. See
Plaintiff’s Responses t0 Defendant’s Request for Disclosure for additional
information concerning such health—care providers including medical bills and
records relating t0 Plaintiff.
First Supplemental Response:
Defendant hereby designates as an expert Witness the following individual:
Jontel Pierce, MD
11929 University Blvd, #lB
Sugar Land, Texas 77479
28 1 402.9522
Dr. Pierce is a Texas physician and board certified in neurology Who has reviewed Carlos
Vega’s medical records and other case materials provided to her and is expected t0 testify
regarding the extent 0f the 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 DESIGNATION OF EXPERTS -2-
Respectfully submitted,
$f/fl
Chad Kimble, State Bar N0. 24007483
Kyle Smith, State Bar N0. 241025 12
D. Brent Beasley, State Bar N0. 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 OF SERVICE
The undersigned certifies that on the 3 1“ day ofAugust, 2020, a true copy of the foregoing
has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure.
%fl.
Kyle Smith
DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION OF EXPERTS -3-
JONTEI. D. PIERCE, M.D. 12001 N. CENTRAL EXPRESSWAY
AMERICAN BOARD OF PSYCHIATRY AND NEUROLOGY SUITE 800
AMERICAN ACADEMY OF NEUROLOGY DALLAS, TX 75243
(214) 750—61 10
FAX —
(214) 750—5825
Augus’r 20, 2020
Mr. Chad Kimble
Low Chad Kimble, PC.
Office of
1204 Sou’rh Whi’re Chapel Blvd.
Sou’rhloke, TX 76092
RE: Carlos Vega
CLAIM #: 0491031 787
DATE OF INJURY: 02/06/18
CASE #2 21 182707
Dear Mr. Kimble:
| hove had ’rhe opportunity ’ro review medical records on Mr. Carlos Vega.
My name is Jon’rel Pierce, M.D. | om a board certified neurologist.
|earned on M.D. degree from Howard University College of Medicine 0nd ’rhen comple’red a four-yeor
neurology program GT S’r. Louis University.
| provide bo’rh diagnosis 0nd Treo’rmen’r for neurological disorders 0nd also refer my po’rien’rs for a vorie’ry of
o’rher medical services.
The following opinions ore based on reasonable medical probability, utilizing my 4 years of privo’re practice,
relevant medical Ii’rero’rure, 0nd ex’rensive experience in performing case reviews 0nd bill reviews.
SUMMARY OF MEDICAL RECORDS:
The poTien’r was in o moTor vehicle occiden’r on February 6, 2018. He was seen 0T The hospiTol offer The
involved
mo’ror vehicle accident. He was oler’r 0nd oriented x 4 on The scene. He wos in ’rhe driver’s seo’r when he wos hi’r
on ’rhe driver’s side. He wos ’rhe restrained driver. Airbags deployed. There wos no loss of consciousness
reported. He had tenderness of The neck, lower back, shoulder, 0nd knees. He was Transferred To Baylor Dallas.
PoTien’r denied hi’r’ring his head. No windshield damage. Po’rien’r complained of neck 0nd lower back pain. Per
ED position repor’r, ’rhe poTien’r had unknown loss of consciousness 0nd unknown head Trauma. The CT scan of
’rhe head showed no ocu’re in’rrocroniol process 0nd o minimal occipital scalp hemoTomo. The CT scan of The
spine showed no ocu’re froc’rure.
The was seen by Dr. on September H, 2019, complaining of headaches, dizziness, Ief’r ear pain,
Stephen Gis’r
hearing loss, 0nd near syncope. He was diagnosed wi’rh head Trauma wi’rh
blurred vision, confusion episodes,
pos’r—concussive syndrome, 0nd Ief’r ear hearing loss. He was referred for a hearing evaluation and for
neuropsychologicol evaluation.
The patient was seen o’r Buckner Pain 0nd Injury shor’rly of’rer ’rhe accident on February 8, 2018, where he
complained of severe lower back pain, severe neck pain, in’rense rib cage pain, in’rense headaches, 0nd
dizziness daily since ’rhe accident.
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 2 of 9
The patient was seen at Momentum Spine & Joint on February 22, 2018, complaining of muscle tightness,
restricted motion, aching pain throughout the neck and low back to the legs and now stating he had loss of
consciousness during the motor vehicle accident. He was diagnosed with cervical and lumbar radiculopathy,
right elbow pain, and pain in the left knee.
The patient was seen at Buckner Pain and Injury on April 24, 2018, where he was discharged from their care.
On January 15, 2020, he had an operative report for a lumbar epidural steroid injection at the right L4-L5.
On July 16, 2019, the patient was seen at Momentum Spine & Joint with reports of persistent pain in the cervical
and lumbar spine, right elbow pain, and left knee pain. Headaches were throbbing and there was numbness
and tingling in the right arm.
On August 15, 2019, the patient underwent a lumbar epidural steroid injection to the left L5-S1.
The patient had a follow-up appointment with Momentum Spine & Joint on September 5, 2019. He had a
routine electroencephalography done which was normal.
He was seen at Medical Specialists Associates on September 19, 2019, where he complained of difficulty
hearing from his left ear. He was diagnosed with ototoxic hearing loss of the left ear and bilateral hearing loss.
The left hearing loss was felt to be due to the accident.
The patient had a Functional Capacity Exam on September 30, 2019, which showed he was restricted from any
weightlifting.
The patient had an MRI scan of the brain done on September 30, 2019, which was unremarkable.
The patient was seen at Elevated Health Clinics on October 10, 2019, stating not much improvement in
symptoms and still having headaches at night. Recommendations were cognitive assessment and VNG.
He had Vault Testing on October 14, 2019.
He had a follow-up with neurology on November 11, 2019, complaining of post-traumatic headaches, dizziness,
concentration issues, short term memory impairment, blurry vision, and speech difficulties. He had VNG testing
which showed peripheral vestibular dysfunction and central vestibular dysfunction.
He had a follow-up with neurology, and he states that his dizziness and headaches had improved. His
headaches were reduced and started beta blocker.
The patient had a speech evaluation on December 10, 2019, which was diagnostic cognitive communication
deficit and mild cognitive impairment.
He was seen on December 17, 2019, where he underwent speech therapy.
The patient was seen at Momentum Spine & Joint due to recurrent musculoskeletal pain.
On December 31, 2019, the patient was seen for speech therapy.
On January 28, 2020, the patient was seen for speech therapy.
On November 11, 2020, the patient was seen for speech therapy.
Carlos Vega
Augus’r 18, 2020
CASE #: 21 182707
Page 3 of 9
On March O9, 2020, ’rhe po’rien’r hod 0 neurology follow—up. He s’ro’res ’rhOT his memory had no’r improved. Mood
disturbance continued. He feIT depressed 0nd anxious 0nd cries easily. He does hove 0 previous history of
depression. Headaches had significantly improved.
The patient had speech Therapy on April 10, 2020.
The po’rien’r hod o neurology follow—up where he sTo’red That his dizziness 0nd headaches had significantly
improved.
OPINION:
From my review of ’rhe records, ’rhe patient had o on February 6, 2018, 0nd he ini’riolly
mo’ror vehicle occiden’r
did no’r repor’rony head Trauma or loss of consciousness; however, he did hove 0n occipi’rol scalp hemo’romo
’rho’r was found on o CT of The head indicating Tho’r he likely suffered from a head confusion. Regarding ’rhe
necessity ofTreonenT o’r Behavioral Heol’rh Clinics and ElevoTe Heol’rh Clinics, ’rhe TreonenT 0T These ins’riTu’rions
were unreasonable 0nd unnecessary. He did no’r complain of any headaches unTiI he wen’r ’ro ’rhe Buckner
Pain 0nd Injury on February 8, 2018. Fur’rhermore, he was discharged from The Buckner Pain 0nd Injury on April
24, 2018. He did no’r seek neurological core o’r Elevo’red Heol’rh Clinics un’ril SepTember 2019, ’rhis was over o
year 0nd c1 half from The day of injury. Therefore, given ThoT he had suffered from a head confusion his
sympToms should hove resolved wiThin 2 weeks from The moTor vehicle accident Having These prolonged
sympToms offer o head confusion is very unlikely 0nd no’r supporfed by The medical documen’ro’rion or medical
evidence. FurThermore, given ThoT he is having These cogni’rive changes 0nd speech disturbance o year a holf
offer o head confusion, This is also highly unlikely given The lock of severi’ry of ’rhe head confusion. Therefore,
These pos’r—concussive sympToms including ’rhe cogniTive complain’rs ore unlikely reloTed ’ro ’rhe mo’ror vehicle
occiden’r on February 6, 2018.
Regarding ’rhe reasonable chorges/pricing of Elevo’re Heol’rh Clinics, The charges were unreasonable, 0nd They
were excessive compared ’ro The normal charges in Their area.
—
The charge for ’rhe EEG using CPT code 9581 6 on 9/9/19, was excessive 0nd unreasonable. The EEG was
charged 0T $3,000.00. The average cos’r in ’rhe oreo for o routine EEG is $1 ,OO0.00.
—
The charge for The consulTo’rion on 9/9/19 using CPT code 99204 for $950.00 was excessive 0nd
unreasonable. Average cost for o level 4 consulfo’rion in ThoT oreo is $500.00.
—
The cos’r of The OV refroc’rion using CPT code 92015 on Sep’rember 23, 2019, was $300.00 0nd is wiThin
reasonable range.
—
The charge of The eye exam new poTienT visiT of $1 ,1 50.00 using CPT code 92004 on SepTember 23, 201 9,
is excessive 0nd unreasonable. The average cos’r in ’rhe oreo of ThoT exam is around $400.00.
—
The charge of The follow—Up office visi’r using CPT code 99214, level 4, on OcTober 10, 2019 0nd 4/28/20,
o’r $750.00 is excessive 0nd unreasonable. The average cosT for o level 4 follow—Up visiT in Tho’r area is
Ground $300.00.
—
The cos’r of The neuropyschology Testing using CPT code 96138 on Oc’rober 14, 2019, 0T $475.00 is
excessive 0nd unreasonable. The average cosT in Tho’r oreo is $300.00.
-
The cos’r of The speech 0nd language evaluation using CPT code 92523 on Oc’rober 14, 2019, GT
$1 ,3] 0.00 is excessive 0nd unreasonable. The average cos’r in Tho’r area is $400.00.
-
The cos’r of The vestibular ’res’ring using CPT code 92537 on November H, 2019, of $830.00 is excessive
0nd unreasonable. The average cos’r of This is $300.00.
-
The charge for ’rhe supplemental electrical ’res’r on November 1, 2019 using CPT code 92547 of $600, is
1
excessive and unreasonable. The average cos’r for ’rhis in ’rhe area is about $200.00.
-
The cos’r of ’rhe vestibular function ’res’rs using CPT code 92540 on November H, 2019, of $980.00 is
excessive and unreasonable. The average cos’r of ’rhis ’res’r is Ground $300.00 in Tho’r area.
—
The cos’r of ’rhe speech therapy visi’rs s’rar’ring on 11/1 1/19, 12/10/19, 12/17/19, 12/31/19, 1/28/20, 2/1 1/20,
4/1 O/2O using CPT code 92507of $525.00 is excessive 0nd unreasonable. The average cos’rs for These visi’rs
ore $200.00 each.
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 4 of 9
- The costs of the sinusoidal rotational test using CPT code 92546 on November 11, 2019, is excessive and
unreasonable. The test was charged $1,670.00. The average cost of this is $300.00.
- The office visit charge using CPT code 99213, level 3, on 11/11/19 and 12/10/19, at $465.00 is excessive
and unreasonable as the average cost of this is around $200.00.
- The office visit charge using CPT code 99215 on 3/9/20 at $900 is excessive and unreasonable. The
average cost in the area is $350.
The charges made by Behavioral Health Clinics were reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96116 for $232.50 was reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96121 for $697.50 was reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96138 of $91 was reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96139 for $1456 for 16 units was reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96132 for $232.50 was reasonable and not excessive.
- The charge on 10/8/19 using CPT code 96133 for $1162.50 for 5 units was reasonable and not excessive.
Regarding the future treatment and costs, in my opinion, the patient had significant improvement in his
symptoms on April 24, 2018, when he was discharged from Buckner Pain and Injury Clinic. Given that he likely
suffered from a head contusion the symptoms likely resolved within 2 weeks of the motor vehicle accident.
Therefore, I do not foresee any future treatment and cost related to the motor vehicle accident on February 6,
2018.
Thank you for the opportunity to review the medical records on Mr. Carlos Vega.
Dictated, reviewed, opinion verified, and attested to by my original signature.
Sincerely,
Mgm “Rum.
%
Jontel D. Pierce, M.D.
American Board of Psychiatry and Neurology
American Academy of Neurology
Q7452
JDP/ck/pl
The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the
basis of the medical records provided, with the assumption that the material is true and correct. If more
information becomes available at a later date, an additional service/report/reconsideration may be
requested.
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 5 of 9
SUMMARY OF RECORDS
Texas Department of Transportation, Jim Hollis, 02/20/18
Texas Peace Officer’s Crash Report, Jacob DeLoof, ID# 10492, 02/06/18
Pre-Hospital Care Report Summary, Dallas Fire-Rescue, Dustin Mobley, EMT, 02/06/18
Baylor University Medical Center, Kyongdeuk Kang, M.D., 02/06/18
Buckner Pain and Injury, Tony VanZant, D.C., 02/08/18, 02/09/18, 02/12/18, 02/13/18, 02/14/18, 02/15/18,
02/16/18, 02/19/18, 02/20/18, 02/21/18, 02/27/18, 02/28/18, 03/03/18, 03/05/18, 03/06/18, 03/09/18,
03/12/18, 03/13/18, 03/19/18, 03/21/18, 03/27/18, 03/28/18, 04/05/18, 04/09/18, 04/24/18
Coast to Coast Radiology Consulting, Kenneth N. Hansen, D.C., 02/12/18
Momentum Spine & Joint, Christopher Chun, M.D. / Kenneth Choi, M.D. / David Sheng, M.D. / Ned
Urbiztondo, M.D., 02/22/18, 03/12/18, 07/16/19, 08/15/19, 09/05/19, 12/20/19, 02/03/20, 04/07/20, 04/10/20
PRiME, Nicholas G. Iwasko, M.D., 03/06/18, 04/22/20
Elevate Health Clinics, Mandeep Chacil, M.D. / Margaret Woodley, P.A.-C. / Vinit Mehrotra, M.D.,
09/09/19, 09/23/19, 10/10/19, 10/14/19, 11/11/19, 12/10/19, 12/17/19, 12/31/19, 01/28/20, 02/11/20,
03/09/20, 04/28/20
Medical Specialists Associated, Stephen Gist, M.D., 09/11/19, 09/19/19
Premier Vision of Dallas, Karen Allen, O.D., 09/23/19
Injury::1, Unidentified, M.D., 09/23/19
MRI Centers of Texas, Matthew Dang, M.D., 09/30/19
Affidavit of Records Custodian of JTP Diagnostics, LLC Regarding Patient Carlos Vega, Natalie Villa,
Custodian of Records, 01/29/19
Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela
Rosales, Custodian of Records, 02/09/19
Affidavit of Records Custodian of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Natalie
Villa, Custodian of Records, 01/29/19
Medical Records Affidavit of Coast to Coast Radiology Consulting Regarding Patient Carlos Vega, Ken
Hansen, D.C., Custodian of Records, 01/28/19
Medical Records Affidavit of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela Rosales,
Custodian of Records, 02/09/19
Copy of Texas Identification Card, Carlos Vega, Iss: 01/17/15; Exp: 10/24/19
Medical Records Affidavit of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Natalie Villa,
Custodian of Records, 01/29/19
Affidavit for American Radiology Consultants, Cheryl Granger, Custodian of Billing Records, 02/02/19
Affidavit of Records Custodian of Baylor University Medical Center Regarding Patient Carlos Vega,
Cynthia Faulker, Custodian of Records, 03/20/18
Affidavit of Records Custodian of Buckner Pain & Injury Regarding Patient Carlos Vega, Heaven Rubio,
Custodian of Records, 01/31/19
Affidavit of Records Custodian of Century Integrated Partners, Inc., Regarding Patient Jessica Blankson
Lartey, Custodian of Records, 03/15/18
Affidavit of Medical Expenses, Fran Cuzzo, Custodian of Records for City of Dallas EMS, 02/25/19
Affidavit of Records Custodian of DFW Diagnostics Regarding Patient Carlos Vega, Vanessa Urias,
Custodian of Records, 01/29/19
Correspondence-Eberstein Witherite, Casey E. Kummell, 04/17/19, 09/09/19, 10/25/19, 11/20/19,12/13/19,
Plaintiff’s Rule 194 Disclosure, 04/17/19
Plaintiff’s Objections and Answers to Defendant Josefina Vazquez’s First Set of Interrogatories and
Objections and Responses to First Request for Production, 04/17/19
Verification, Carlos Vega, 04/17/19
Medical Records Affidavit, Custodian of Medical Records for Baylor University Medical Center at Dallas,
Margie L. Powe, 03/14/18
Medical Records Affidavit, of Buckner Pain & Injury, Regarding Patient Carlos Vega, Heaven Rubio,
Custodian of Medical Records, 01/31/19
Plaintiff’s Fourth Supplemental Rule 194 Disclosure, 12/13/19
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 6 of 9
Direct Questions to be propounded to the Witness, 08/19/19
Officer’s Certification, Rolando Lopez, Custodian of Records for Cricket Wireless (PhoneRecords)10/02/19
Medical Records Affidavit, of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega, Kusha
Josef, Custodian of Records, 11/20/19
Medical Records Affidavit, of Stephen E. Gist, M.D., Regarding Patient Carlos Vega, Erica Moore,
Custodian of Records, 11/14/19
Medical Records Affidavit, of Injury 1 of Dallas, Regarding Patient Carlos Vega, Erica Moore, Custodian
of Records, 10/09/19
Affidavit of Records Custodian of Behavioral Health Providers Regarding Patient Carlos Vega, Judith
Guerra, Custodian of Records, 11/20/19
Affidavit of Records Custodian of Elevate Health Clinics, LLC-Dallas Regarding Patient Carlos Vega,
Kusha Joseph, Custodian of Records, 11/20/19
Affidavit of Records Custodian of Stephen E. Gist, M.D. Regarding Patient Carlos Vega, Erica Moore,
Custodian of Records, 11/14/19
Affidavit of Records Custodian of MetroCare Regarding Patient Carlos Vega, Shea Abraham, Custodian
of Records, 09/11/19
Correspondence-Witherite Law Group, Casey E. Kummell, 05/01/20
Plaintiff’s Sixth Supplemental Rule 194 Disclosure, 05/01/20
Medical Records Affidavit, of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega, Kusha
Josef, Custodian of Records, 05/01/20
Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela
Rosales, Custodian of Records, 05/01/20
Color Photo Texas ID Card, Carlos Vega, Iss: 01/17/15 Exp: 10/24/19
Medical Records Affidavit, of Prime Diagnostic Imaging, Regarding Patient Carlos Vega, Yasmine
Garcia, Custodian of Records, 04/29/20
Affidavit of Records Custodian of Elevate Health Clinics, LLC, Regarding Patient Carlos Vega, Kusha
Josef, Custodian of Records, 05/01/20
Affidavit of Records Custodian of JTP Diagnostics, LLC, Regarding Patient Carlos Vega, Yasmine Garcia,
Custodian of Records, 04/29/20
Affidavit of Records Custodian of Uptown Radiology Associates Regarding Patient Carlos Vega, Karma
Fernandez, Custodian of Records, 04/29/20
Radiology Records Affidavit of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Yasmine
Garcia, Custodian of Records, 04/29/20
Plaintiff’s Third Supplemental Rule 194 Disclosure, 11/20/19
Plaintiff’s Second Supplemental Rule 194 Disclosure, 10/25/19
Medical Records Affidavit, of Elevate Health Clinics, Regarding Patient Carlos Vega, Kusha Josef,
Custodian of Medical Records, 10/10/19
Medical Records Affidavit, of Momentum Spine & Joint, Regarding Patient Carlos Vega, Tamela
Rosales, Custodian of Medical Records, 10/04/19Medical Records Affidavit, of MRI Centers of Texas,
Regarding Patient Carlos Vega, Adriana Ledesma, Custodian of Medical Records, 10/11/19
Affidavit of Records Custodian of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega,
Kusha Josef, Custodian of Records, 10/10/19
Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela
Rosales, Custodian of Records, 10/04/19
Affidavit of Records Custodian of MRI Centers of Texas, Regarding Patient Carlos Vega, Adriana
Ledesma, Custodian of Records, 10/11/19
Radiology Records Affidavit of MRI Centers of Texas Regarding Patient Carlos Vega, Adriana Ledesma,
Custodian of Records, 10/11/19
Plaintiff’s First Supplemental Rule 194 Disclosure, 09/09/19
Radiology Records Affidavit of Baylor University Medical Center Regarding Patient Carlos Vega, Samuel
Malhew, Custodian of Records, 05/22/19
Color Photographs, 4-Pages, 00/00/00
Itemized Statement, JTP Diagnostics, LLC, Statement Date: 01/28/19, Date of Service: 03/06/18
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 7 of 9
Itemized Statement, Momentum Spine & Joint, Statement Date: 02/07/19, Date of Service: 02/22/18-
03/12/18
Health Insurance Claim Form, Momentum Spine & Joint, 02/22/18, (99203)
Health Insurance Claim Form, Momentum Spine & Joint, 03/12/18, (9 9213)
Estimated Bill of Services, Momentum Spine & Joint, 00/00/00
Itemized Statement, American Radiology Consultants, , Statement Date: 02/02/19, Date of Service:
02/06/18
Itemized Statement, Baylor University Medical Center, Statement Date: 03/19/18, Date of Service:
02/06/18-03/10/18
Patient Account Ledger, Baylor University Medical Center, Ledger Date: 03/20/18, Date of Service:
02/06/18
Patient Account Ledger, Buckner Pain and Injury, Ledger Date: 06/29/18, Date of Service: 02/08/18-
04/24/18
Health Insurance Claim Form, Buckner Pain and Injury, 02/08/18 (A4556); 02/08/18 (99080); 02/08/18
(99203); 02/08/18 (97014); 02/08/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 02/08/18 (97010); 02/08/18 (97140); 02/08/18
(97035); 02/09/18 (97014); 02/09/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 02/09/18 (97010); 02/09/18 (97140); 02/09/18
(97035); 02/12/18 (97014); 02/12/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 02/12/18 (97010); 02/12/18 (97140); 02/12/18
(97035); 02/13/18 (97014); 02/13/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 02/13/18 (97010); 02/13/18 (97140); 02/13/18
(97035); 02/14/18 (97014); 02/14/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 02/14/18 (97010); 02/14/18 (97140); 02/14/18
(97035); 02/14/18 (97110); 02/14/18 (97014)
Health Insurance Claim Form, Buckner Pain and Injury, 02/15/18 (97012); 02/15/18 (97010); 02/15/18
(97140); 02/15/18 (97035); 02/15/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 02/16/18 (97014); 02/16/18 (97012); 02/16/18
(97010); 02/16/18 (97035)
Health Insurance Claim Form, Buckner Pain and Injury, 02/16/18 (97110); 02/19/18 (97014); 02/19/18
(97012); 02/19/18 (97010); 02/19/18 (97140)
Health Insurance Claim Form, Buckner Pain and Injury, 02/19/18 (97035); 02/19/18 (97110); 02/20/18
(97014); 02/20/18 (97012); 02/20/18 (97010)
Health Insurance Claim Form, Buckner Pain and Injury, 02/20/18 (97140); 02/20/18 (97035); 02/20/18
(97110); 02/21/18 (99213); 02/21/18 (97014)
Health Insurance Claim Form, Buckner Pain and Injury, 02/21/18 (97012); 02/21/18 (97010); 02/21/18
(97140); 02/21/18 (97035); 02/21/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 02/27/18 (97014); 02/27/18 (97012); 02/27/18
(97140); 02/27/18 (97035); 02/27/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 02/28/18 (97014); 02/28/18 (97012); 02/28/18
(97140); 02/28/18 (97035); 02/28/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/03/18 (97014); 03/03/18 (97012); 03/03/18
(97140); 03/03/18 (97035); 03/03/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/05/18 (97014); 03/05/18 (97012); 03/05/18
(97140); 03/05/18 (97035); 03/05/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/06/18 (97014); 03/06/18 (97012); 03/06/18
(97140); 03/06/18 (97035); 03/06/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/09/18 (97014); 03/09/18 (97012); 03/09/18
(97140); 03/09/18 (97035); 03/09/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/12/18 (97014); 03/12/18 (97012); 03/12/18
(97140); 03/12/18 (97035); 03/12/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/13/18 (97014); 03/13/18 (97012); 03/13/18
(97140); 03/13/18 (97035); 03/13/18 (97110)
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 8 of 9
Health Insurance Claim Form, Buckner Pain and Injury, 03/19/18 (97012); 03/19/18 (97140); 03/19/18
(97035); 03/19/18 (97110); 03/21/18 (99213)
Health Insurance Claim Form, Buckner Pain and Injury, 03/21/18 (97014); 03/21/18 (97012); 03/21/18
(97140); 03/21/18 (97035); 03/21/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/27/18 (97014); 03/27/18 (97012); 03/27/18
(97140); 03/27/18 (97035); 03/27/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 03/28/18 (97014); 03/28/18 (97012); 03/28/18
(97140); 03/28/18 (97035); 03/28/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 04/05/18 (97014); 04/05/18 (97012); 04/05/18
(97140); 04/05/18 (97035); 04/05/18 (97110)
Health Insurance Claim Form, Buckner Pain and Injury, 04/09/18 (97012); 04/09/18 (97140); 04/09/18
(97035); 04/09/18 (97110); 04/24/18 (97012)
Health Insurance Claim Form, Buckner Pain and Injury, 04/24/18 (97140); 04/24/18 (97110); 04/24/18
(99080)
Health Insurance Claim Form, Baylor University Medical Center, 02/06/18
Itemized Statement, City of Dallas, Statement Date: 02/20/20, Date of Service: 02/06/18
Itemized Statement, Coast to Coast Radiology Consulting, Statement Date: 02/25/18, Date of Service:
02/12/18
Patient Ledger-DFW Diagnostics, Unidentified, M.D., Ledger Date: 03/17/18, Date of Service: 02/09/18
Health Insurance Claim Form, DFW Diagnostics, 02/09/18, (72050); 02/09/18, (72070); 02/09/18, (72100)
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Billing Review, Dallas Fire-Rescue, Dustin Mobley, Paramedic, Review Date: 02/06/18, Date of Service:
02/06/18
Patient Account History, Behavioral Health Providers, Summary Date: 10/08/19, Date of Service:
10/08/19
Health Insurance Claim Form, Behavioral Health Providers, 10/08/19, (9 6 1 1 6); 10/08/19, (96121);
10/08/19, (96138); 10/08/19, (96139); 10/08/19, (96132); 10/08/19, (96133)
Itemized Statement, Elevate HC Texas, Statement Date: 11/20/19, Date of Service: 09/09/19-11/11/19
Health Insurance Claim Form, Elevate HC Texas, 09/09/19, (95816)
Health Insurance Claim Form, Elevate HC Texas, 09/09/19, (99204)
Health Insurance Claim Form, Elevate HC Texas, 09/23/19, (92015)
Health Insurance Claim Form, Elevate HC Texas, 09/23/19, (92004)
Health Insurance Claim Form, Elevate HC Texas, 10/10/19, (99214)
Health Insurance Claim Form, Elevate HC Texas, 10/14/19, (96138)
Health Insurance Claim Form, Elevate HC Texas, 10/14/19, (92523)
Patient Account History, Injury 1 Dallas, Summary Date: 09/11/19, Date of Service: 03/08/11-11/14/19
Health Insurance Claim Form, Medical Specialists Associated, 09/19/19 (9 9 2 1 3); 09/19/19 (92552)
Patient Ledger-MetroCare Services, Unidentified, M.D., Ledger Date: 09/11/19, Date of Service:
12/12/18-07/31/19
Itemized Statement, MetroCare Services, Statement Date: 09/11/19, Date of Service: 02/06/18-
12/01/18
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Itemized Statement, Elevate HC Texas, Statement Date: 05/01/20, Date of Service: 09/09/19-04/28/20
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92537)
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92547)
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92540)
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92507)
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92546)
Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (99213)
Carlos Vega
August 18, 2020
CASE #: 21182707
Page 9 of 9
Health Insurance Claim Form, Elevate HC Texas, 12/10/19, (92507)
Health Insurance Claim Form, Elevate HC Texas, 12/10/19, (99213)
Health Insurance Claim Form, Elevate HC Texas, 12/17/19, (92507)
Health Insurance Claim Form, Elevate HC Texas, 12/31/19, (92507)
Health Insurance Claim Form, Elevate HC Texas, 01/28/20, (92507)
Health Insurance Claim Form, Elevate HC Texas, 02/11/20, (92507)
Health Insurance Claim Form, Elevate HC Texas, 03/09/20, (92507)
Health Insurance Claim Form, Elevate HC Texas, 03/09/20, (99215)
Health Insurance Claim Form, Elevate HC Texas, 04/10/20, (92507)
Health Insurance Claim Form, Elevate HC Texas, 04/28/20, (99214)
Itemized Statement, JTP Diagnostics, Statement Date: 04/29/20, Date of Service: 03/06/18-04/22/20
Itemized Statement, Momentum Spine & Joint, Statement Date: 04/29/20, Date of Service: 02/22/18-
04/07/20
Health Insurance Claim Form, Momentum Spine & Joint, 07/16/19, (9 9 2 1 3)
Health Insurance Claim Form, Momentum Spine &Joint, 08/15/19, (99213)
Health Insurance Claim Form, Momentum Spine &Joint, 08/15/19, (64483); 08/15/19, (20605); 08/15/19,
(77002)
Health Insurance Claim Form, Momentum Spine & Joint, 09/05/19, (9 9 2 1 3)
Health Insurance Claim Form, Momentum Spine & Joint, 12/20/19, (9 9 2 1 3)
Health Insurance Claim Form, Momentum Spine & Joint, 01/15/20, (64483)
Health Insurance Claim Form, Momentum Spine & Joint, 02/03/20, (9 9 2 1 2)
Health Insurance Claim Form, Momentum Spine & Joint, 04/07/20, (9 9 2 1 4)
Itemized Statement, Uptown Radiology Associates, Statement Date: 04/29/20, Date of Service:
09/30/19
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Itemized Statement, Uptown Radiology Associates, Statement Date: 10/23/19, Date of Service:
09/30/19
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Estimated Bill of Services-Lumbar transforaminal epidural steroid injection,L5-S1, Momentum Spine &
Joint, 00/00/00
Estimated Bill of Services-Momentum Spine & Joint, Right Elbow Injection, Unidentified, M.D., Estimate
Date: 00/00/00
Itemized Statement, Elevate HC Texas, Statement Date: 10/09/19, Date of Service: 09/09/19
Itemized Statement, Momentum Spine & Joint, Statement Date: 09/23/19, Date of Service: 02/22/18-
09/05/19
Health Insurance Claim Form, MRI Centers of Texas, 09/30/19, (70551)
Patient Ledger-MRI Centers of Texas, Unidentified, M.D., Ledger Date: 00/00/00, Date of Service:
09/30/19
Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of
Service: 00/00/00
Professional Experience
I
MIND Headache and Neurology PLLC
Treat and manage patients with neurological disorders in an outpatient and
inpatient setting. Experienced in treating various diseases such as multiple
sclerosis, acute stroke, seizures, neuropathy, migraines, back pain, dementia,
traumatic brain injury, and Parkinson’s disease.
Proficient in reading and interpreting EEGs.
Proficient in concussion diagnosis and management
CEO/Neuro/ogist- January 201 7- Present
Veterans Evaluation Services-
Evaluate veterans with suspected traumatic brain injury and other service
connected neurological conditions.
December 2016 to Present
Hospital Docs, PA- Conroe Regional Medical Center
Neurohospitalist — August 201 6- December 2016
Saint Louis University- Department of Neurology and Psychiatry
Resident Physician- June 2012-June 2016
Training and Education
I
Saint Louis University
July 2012- June 2016
Adult Neurology Residency Program
Howard University College of Medicine
July 2008- June 2012
Doctor of Medicine Degree
Hampton University
July 2003- May 2007
Bachelor of Science
ACLS Certified
Cosmetic Botox and derma/fi/ler Certificate
IAttending Neurologist
5t. Luke’s Sugar Land Hospital
North Cypress Medical Center
Memorial Hermann Sugar Land
Pearland Medical Center
I
Professional Membership
A diplomat of the American Board of Psychiatry and Neurology
American Academy of Neurology
Houston Medical Forum
Poster Presentations and Research
I
NIH Summer Research Program Poster Day
Delta Opioid Receptor Agonist: Possible Treatment for Anxious Major
Depressive Disorder
Automated
Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Chad Kimble
Bar No. 24007483
eservice@chadkimblelaw.com
Envelope ID: 45846327
Status as of 9/1/2020 2:59 PM CST
Associated Case Party: CARLOS VEGA
Name BarNumber Email TimestampSubmitted Status
Jibraeel Zaidi Jib.Zaidi@witheritelaw.com 8/31/2020 3:51 :54 PM SENT
Christal Bables Christal.bables@witheritelaw.com 8/31/2020 3:51 :54 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Gaby Velasquez gabyv@diazlf.com 8/31/2020 3:51 :54 PM SENT
Associated Case Party: JOSEFINA VAZQUEZ
Name BarNumber Email TimestampSubmitted Status
Kyle Smith eservice@chadkimblelaw.com 8/31/2020 3:51 :54 PM SENT
Preview
FILED 8/31/2020 3:51 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Veronica Vaughn DEPUTY N0. DC-19-01170 CARLOS VEGA § IN THE DISTRICT COURT PLAINTIFF, § § VS. § DALLAS COUNTY, TEXAS § JOSEFINA VASQUEZ § DEFENDANT. § 298TH JUDICIAL DISTRICT DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION 0F EXPERTS Pursuant t0 TeX R. Civ. P. 194, Defendant serves the following First Supplemental 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 0f the basis for them, 0r if the expert is not retained by, employed by, 0r otherwise subject t0 the control of the responding party, documents reflecting such information; 4. Ifthe expert is retained by, employed by, or otherwise subject t0 the control 0f the responding party: A. A11 documents, tangible things, reports, models, 0r data compilations that have been provided reviewed by, 0r prepared by or for the t0, 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 to call any expert Witness(es) designated by any other party t0 this case, as well as any experts later designated by any party to this case on any subject relevant to this litigation on which the Witness is qualified t0 testify. In the event that any party t0 this cause has designated any experts but has been 0r is subsequently dismissed for any reason 0r fails to call any designated expert at the time of trial, Defendant specifically reserves the right t0 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 to positively aver that such previously designated expert will not be called as a Witness at trial and t0 redesignate same as a consulting expert who will not be called by any party in this cause. Finally, Defendant reserves the right DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION OF EXPERTS -1- 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 0r 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 0f any such Witnesses 0r their opinions, or the reliability, materiality, 0r admissibility 0f information and/or tangible things produced by these individuals in general; by this designation Defendant is simply reserving the opportunity t0 rely upon or elicit certain opinions and/or evidence from these Witnesses t0 the extent that it deems it in its interest t0 do so. Such persons are expected t0 testify concerning Plaintiff’ s care and treatment. See Plaintiff’s Responses t0 Defendant’s Request for Disclosure for additional information concerning such health—care providers including medical bills and records relating t0 Plaintiff. First Supplemental Response: Defendant hereby designates as an expert Witness the following individual: Jontel Pierce, MD 11929 University Blvd, #lB Sugar Land, Texas 77479 28 1 402.9522 Dr. Pierce is a Texas physician and board certified in neurology Who has reviewed Carlos Vega’s medical records and other case materials provided to her and is expected t0 testify regarding the extent 0f the 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 DESIGNATION OF EXPERTS -2- Respectfully submitted, $f/fl Chad Kimble, State Bar N0. 24007483 Kyle Smith, State Bar N0. 241025 12 D. Brent Beasley, State Bar N0. 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 OF SERVICE The undersigned certifies that on the 3 1“ day ofAugust, 2020, a true copy of the foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. %fl. Kyle Smith DEFENDANT’S FIRST SUPPLEMENTAL DESIGNATION OF EXPERTS -3- JONTEI. D. PIERCE, M.D. 12001 N. CENTRAL EXPRESSWAY AMERICAN BOARD OF PSYCHIATRY AND NEUROLOGY SUITE 800 AMERICAN ACADEMY OF NEUROLOGY DALLAS, TX 75243 (214) 750—61 10 FAX — (214) 750—5825 Augus’r 20, 2020 Mr. Chad Kimble Low Chad Kimble, PC. Office of 1204 Sou’rh Whi’re Chapel Blvd. Sou’rhloke, TX 76092 RE: Carlos Vega CLAIM #: 0491031 787 DATE OF INJURY: 02/06/18 CASE #2 21 182707 Dear Mr. Kimble: | hove had ’rhe opportunity ’ro review medical records on Mr. Carlos Vega. My name is Jon’rel Pierce, M.D. | om a board certified neurologist. |earned on M.D. degree from Howard University College of Medicine 0nd ’rhen comple’red a four-yeor neurology program GT S’r. Louis University. | provide bo’rh diagnosis 0nd Treo’rmen’r for neurological disorders 0nd also refer my po’rien’rs for a vorie’ry of o’rher medical services. The following opinions ore based on reasonable medical probability, utilizing my 4 years of privo’re practice, relevant medical Ii’rero’rure, 0nd ex’rensive experience in performing case reviews 0nd bill reviews. SUMMARY OF MEDICAL RECORDS: The poTien’r was in o moTor vehicle occiden’r on February 6, 2018. He was seen 0T The hospiTol offer The involved mo’ror vehicle accident. He was oler’r 0nd oriented x 4 on The scene. He wos in ’rhe driver’s seo’r when he wos hi’r on ’rhe driver’s side. He wos ’rhe restrained driver. Airbags deployed. There wos no loss of consciousness reported. He had tenderness of The neck, lower back, shoulder, 0nd knees. He was Transferred To Baylor Dallas. PoTien’r denied hi’r’ring his head. No windshield damage. Po’rien’r complained of neck 0nd lower back pain. Per ED position repor’r, ’rhe poTien’r had unknown loss of consciousness 0nd unknown head Trauma. The CT scan of ’rhe head showed no ocu’re in’rrocroniol process 0nd o minimal occipital scalp hemoTomo. The CT scan of The spine showed no ocu’re froc’rure. The was seen by Dr. on September H, 2019, complaining of headaches, dizziness, Ief’r ear pain, Stephen Gis’r hearing loss, 0nd near syncope. He was diagnosed wi’rh head Trauma wi’rh blurred vision, confusion episodes, pos’r—concussive syndrome, 0nd Ief’r ear hearing loss. He was referred for a hearing evaluation and for neuropsychologicol evaluation. The patient was seen o’r Buckner Pain 0nd Injury shor’rly of’rer ’rhe accident on February 8, 2018, where he complained of severe lower back pain, severe neck pain, in’rense rib cage pain, in’rense headaches, 0nd dizziness daily since ’rhe accident. Carlos Vega August 18, 2020 CASE #: 21182707 Page 2 of 9 The patient was seen at Momentum Spine & Joint on February 22, 2018, complaining of muscle tightness, restricted motion, aching pain throughout the neck and low back to the legs and now stating he had loss of consciousness during the motor vehicle accident. He was diagnosed with cervical and lumbar radiculopathy, right elbow pain, and pain in the left knee. The patient was seen at Buckner Pain and Injury on April 24, 2018, where he was discharged from their care. On January 15, 2020, he had an operative report for a lumbar epidural steroid injection at the right L4-L5. On July 16, 2019, the patient was seen at Momentum Spine & Joint with reports of persistent pain in the cervical and lumbar spine, right elbow pain, and left knee pain. Headaches were throbbing and there was numbness and tingling in the right arm. On August 15, 2019, the patient underwent a lumbar epidural steroid injection to the left L5-S1. The patient had a follow-up appointment with Momentum Spine & Joint on September 5, 2019. He had a routine electroencephalography done which was normal. He was seen at Medical Specialists Associates on September 19, 2019, where he complained of difficulty hearing from his left ear. He was diagnosed with ototoxic hearing loss of the left ear and bilateral hearing loss. The left hearing loss was felt to be due to the accident. The patient had a Functional Capacity Exam on September 30, 2019, which showed he was restricted from any weightlifting. The patient had an MRI scan of the brain done on September 30, 2019, which was unremarkable. The patient was seen at Elevated Health Clinics on October 10, 2019, stating not much improvement in symptoms and still having headaches at night. Recommendations were cognitive assessment and VNG. He had Vault Testing on October 14, 2019. He had a follow-up with neurology on November 11, 2019, complaining of post-traumatic headaches, dizziness, concentration issues, short term memory impairment, blurry vision, and speech difficulties. He had VNG testing which showed peripheral vestibular dysfunction and central vestibular dysfunction. He had a follow-up with neurology, and he states that his dizziness and headaches had improved. His headaches were reduced and started beta blocker. The patient had a speech evaluation on December 10, 2019, which was diagnostic cognitive communication deficit and mild cognitive impairment. He was seen on December 17, 2019, where he underwent speech therapy. The patient was seen at Momentum Spine & Joint due to recurrent musculoskeletal pain. On December 31, 2019, the patient was seen for speech therapy. On January 28, 2020, the patient was seen for speech therapy. On November 11, 2020, the patient was seen for speech therapy. Carlos Vega Augus’r 18, 2020 CASE #: 21 182707 Page 3 of 9 On March O9, 2020, ’rhe po’rien’r hod 0 neurology follow—up. He s’ro’res ’rhOT his memory had no’r improved. Mood disturbance continued. He feIT depressed 0nd anxious 0nd cries easily. He does hove 0 previous history of depression. Headaches had significantly improved. The patient had speech Therapy on April 10, 2020. The po’rien’r hod o neurology follow—up where he sTo’red That his dizziness 0nd headaches had significantly improved. OPINION: From my review of ’rhe records, ’rhe patient had o on February 6, 2018, 0nd he ini’riolly mo’ror vehicle occiden’r did no’r repor’rony head Trauma or loss of consciousness; however, he did hove 0n occipi’rol scalp hemo’romo ’rho’r was found on o CT of The head indicating Tho’r he likely suffered from a head confusion. Regarding ’rhe necessity ofTreonenT o’r Behavioral Heol’rh Clinics and ElevoTe Heol’rh Clinics, ’rhe TreonenT 0T These ins’riTu’rions were unreasonable 0nd unnecessary. He did no’r complain of any headaches unTiI he wen’r ’ro ’rhe Buckner Pain 0nd Injury on February 8, 2018. Fur’rhermore, he was discharged from The Buckner Pain 0nd Injury on April 24, 2018. He did no’r seek neurological core o’r Elevo’red Heol’rh Clinics un’ril SepTember 2019, ’rhis was over o year 0nd c1 half from The day of injury. Therefore, given ThoT he had suffered from a head confusion his sympToms should hove resolved wiThin 2 weeks from The moTor vehicle accident Having These prolonged sympToms offer o head confusion is very unlikely 0nd no’r supporfed by The medical documen’ro’rion or medical evidence. FurThermore, given ThoT he is having These cogni’rive changes 0nd speech disturbance o year a holf offer o head confusion, This is also highly unlikely given The lock of severi’ry of ’rhe head confusion. Therefore, These pos’r—concussive sympToms including ’rhe cogniTive complain’rs ore unlikely reloTed ’ro ’rhe mo’ror vehicle occiden’r on February 6, 2018. Regarding ’rhe reasonable chorges/pricing of Elevo’re Heol’rh Clinics, The charges were unreasonable, 0nd They were excessive compared ’ro The normal charges in Their area. — The charge for ’rhe EEG using CPT code 9581 6 on 9/9/19, was excessive 0nd unreasonable. The EEG was charged 0T $3,000.00. The average cos’r in ’rhe oreo for o routine EEG is $1 ,OO0.00. — The charge for The consulTo’rion on 9/9/19 using CPT code 99204 for $950.00 was excessive 0nd unreasonable. Average cost for o level 4 consulfo’rion in ThoT oreo is $500.00. — The cos’r of The OV refroc’rion using CPT code 92015 on Sep’rember 23, 2019, was $300.00 0nd is wiThin reasonable range. — The charge of The eye exam new poTienT visiT of $1 ,1 50.00 using CPT code 92004 on SepTember 23, 201 9, is excessive 0nd unreasonable. The average cos’r in ’rhe oreo of ThoT exam is around $400.00. — The charge of The follow—Up office visi’r using CPT code 99214, level 4, on OcTober 10, 2019 0nd 4/28/20, o’r $750.00 is excessive 0nd unreasonable. The average cosT for o level 4 follow—Up visiT in Tho’r area is Ground $300.00. — The cos’r of The neuropyschology Testing using CPT code 96138 on Oc’rober 14, 2019, 0T $475.00 is excessive 0nd unreasonable. The average cosT in Tho’r oreo is $300.00. - The cos’r of The speech 0nd language evaluation using CPT code 92523 on Oc’rober 14, 2019, GT $1 ,3] 0.00 is excessive 0nd unreasonable. The average cos’r in Tho’r area is $400.00. - The cos’r of The vestibular ’res’ring using CPT code 92537 on November H, 2019, of $830.00 is excessive 0nd unreasonable. The average cos’r of This is $300.00. - The charge for ’rhe supplemental electrical ’res’r on November 1, 2019 using CPT code 92547 of $600, is 1 excessive and unreasonable. The average cos’r for ’rhis in ’rhe area is about $200.00. - The cos’r of ’rhe vestibular function ’res’rs using CPT code 92540 on November H, 2019, of $980.00 is excessive and unreasonable. The average cos’r of ’rhis ’res’r is Ground $300.00 in Tho’r area. — The cos’r of ’rhe speech therapy visi’rs s’rar’ring on 11/1 1/19, 12/10/19, 12/17/19, 12/31/19, 1/28/20, 2/1 1/20, 4/1 O/2O using CPT code 92507of $525.00 is excessive 0nd unreasonable. The average cos’rs for These visi’rs ore $200.00 each. Carlos Vega August 18, 2020 CASE #: 21182707 Page 4 of 9 - The costs of the sinusoidal rotational test using CPT code 92546 on November 11, 2019, is excessive and unreasonable. The test was charged $1,670.00. The average cost of this is $300.00. - The office visit charge using CPT code 99213, level 3, on 11/11/19 and 12/10/19, at $465.00 is excessive and unreasonable as the average cost of this is around $200.00. - The office visit charge using CPT code 99215 on 3/9/20 at $900 is excessive and unreasonable. The average cost in the area is $350. The charges made by Behavioral Health Clinics were reasonable and not excessive. - The charge on 10/8/19 using CPT code 96116 for $232.50 was reasonable and not excessive. - The charge on 10/8/19 using CPT code 96121 for $697.50 was reasonable and not excessive. - The charge on 10/8/19 using CPT code 96138 of $91 was reasonable and not excessive. - The charge on 10/8/19 using CPT code 96139 for $1456 for 16 units was reasonable and not excessive. - The charge on 10/8/19 using CPT code 96132 for $232.50 was reasonable and not excessive. - The charge on 10/8/19 using CPT code 96133 for $1162.50 for 5 units was reasonable and not excessive. Regarding the future treatment and costs, in my opinion, the patient had significant improvement in his symptoms on April 24, 2018, when he was discharged from Buckner Pain and Injury Clinic. Given that he likely suffered from a head contusion the symptoms likely resolved within 2 weeks of the motor vehicle accident. Therefore, I do not foresee any future treatment and cost related to the motor vehicle accident on February 6, 2018. Thank you for the opportunity to review the medical records on Mr. Carlos Vega. Dictated, reviewed, opinion verified, and attested to by my original signature. Sincerely, Mgm “Rum. % Jontel D. Pierce, M.D. American Board of Psychiatry and Neurology American Academy of Neurology Q7452 JDP/ck/pl The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the basis of the medical records provided, with the assumption that the material is true and correct. If more information becomes available at a later date, an additional service/report/reconsideration may be requested. Carlos Vega August 18, 2020 CASE #: 21182707 Page 5 of 9 SUMMARY OF RECORDS Texas Department of Transportation, Jim Hollis, 02/20/18 Texas Peace Officer’s Crash Report, Jacob DeLoof, ID# 10492, 02/06/18 Pre-Hospital Care Report Summary, Dallas Fire-Rescue, Dustin Mobley, EMT, 02/06/18 Baylor University Medical Center, Kyongdeuk Kang, M.D., 02/06/18 Buckner Pain and Injury, Tony VanZant, D.C., 02/08/18, 02/09/18, 02/12/18, 02/13/18, 02/14/18, 02/15/18, 02/16/18, 02/19/18, 02/20/18, 02/21/18, 02/27/18, 02/28/18, 03/03/18, 03/05/18, 03/06/18, 03/09/18, 03/12/18, 03/13/18, 03/19/18, 03/21/18, 03/27/18, 03/28/18, 04/05/18, 04/09/18, 04/24/18 Coast to Coast Radiology Consulting, Kenneth N. Hansen, D.C., 02/12/18 Momentum Spine & Joint, Christopher Chun, M.D. / Kenneth Choi, M.D. / David Sheng, M.D. / Ned Urbiztondo, M.D., 02/22/18, 03/12/18, 07/16/19, 08/15/19, 09/05/19, 12/20/19, 02/03/20, 04/07/20, 04/10/20 PRiME, Nicholas G. Iwasko, M.D., 03/06/18, 04/22/20 Elevate Health Clinics, Mandeep Chacil, M.D. / Margaret Woodley, P.A.-C. / Vinit Mehrotra, M.D., 09/09/19, 09/23/19, 10/10/19, 10/14/19, 11/11/19, 12/10/19, 12/17/19, 12/31/19, 01/28/20, 02/11/20, 03/09/20, 04/28/20 Medical Specialists Associated, Stephen Gist, M.D., 09/11/19, 09/19/19 Premier Vision of Dallas, Karen Allen, O.D., 09/23/19 Injury::1, Unidentified, M.D., 09/23/19 MRI Centers of Texas, Matthew Dang, M.D., 09/30/19 Affidavit of Records Custodian of JTP Diagnostics, LLC Regarding Patient Carlos Vega, Natalie Villa, Custodian of Records, 01/29/19 Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela Rosales, Custodian of Records, 02/09/19 Affidavit of Records Custodian of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Natalie Villa, Custodian of Records, 01/29/19 Medical Records Affidavit of Coast to Coast Radiology Consulting Regarding Patient Carlos Vega, Ken Hansen, D.C., Custodian of Records, 01/28/19 Medical Records Affidavit of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela Rosales, Custodian of Records, 02/09/19 Copy of Texas Identification Card, Carlos Vega, Iss: 01/17/15; Exp: 10/24/19 Medical Records Affidavit of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Natalie Villa, Custodian of Records, 01/29/19 Affidavit for American Radiology Consultants, Cheryl Granger, Custodian of Billing Records, 02/02/19 Affidavit of Records Custodian of Baylor University Medical Center Regarding Patient Carlos Vega, Cynthia Faulker, Custodian of Records, 03/20/18 Affidavit of Records Custodian of Buckner Pain & Injury Regarding Patient Carlos Vega, Heaven Rubio, Custodian of Records, 01/31/19 Affidavit of Records Custodian of Century Integrated Partners, Inc., Regarding Patient Jessica Blankson Lartey, Custodian of Records, 03/15/18 Affidavit of Medical Expenses, Fran Cuzzo, Custodian of Records for City of Dallas EMS, 02/25/19 Affidavit of Records Custodian of DFW Diagnostics Regarding Patient Carlos Vega, Vanessa Urias, Custodian of Records, 01/29/19 Correspondence-Eberstein Witherite, Casey E. Kummell, 04/17/19, 09/09/19, 10/25/19, 11/20/19,12/13/19, Plaintiff’s Rule 194 Disclosure, 04/17/19 Plaintiff’s Objections and Answers to Defendant Josefina Vazquez’s First Set of Interrogatories and Objections and Responses to First Request for Production, 04/17/19 Verification, Carlos Vega, 04/17/19 Medical Records Affidavit, Custodian of Medical Records for Baylor University Medical Center at Dallas, Margie L. Powe, 03/14/18 Medical Records Affidavit, of Buckner Pain & Injury, Regarding Patient Carlos Vega, Heaven Rubio, Custodian of Medical Records, 01/31/19 Plaintiff’s Fourth Supplemental Rule 194 Disclosure, 12/13/19 Carlos Vega August 18, 2020 CASE #: 21182707 Page 6 of 9 Direct Questions to be propounded to the Witness, 08/19/19 Officer’s Certification, Rolando Lopez, Custodian of Records for Cricket Wireless (PhoneRecords)10/02/19 Medical Records Affidavit, of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega, Kusha Josef, Custodian of Records, 11/20/19 Medical Records Affidavit, of Stephen E. Gist, M.D., Regarding Patient Carlos Vega, Erica Moore, Custodian of Records, 11/14/19 Medical Records Affidavit, of Injury 1 of Dallas, Regarding Patient Carlos Vega, Erica Moore, Custodian of Records, 10/09/19 Affidavit of Records Custodian of Behavioral Health Providers Regarding Patient Carlos Vega, Judith Guerra, Custodian of Records, 11/20/19 Affidavit of Records Custodian of Elevate Health Clinics, LLC-Dallas Regarding Patient Carlos Vega, Kusha Joseph, Custodian of Records, 11/20/19 Affidavit of Records Custodian of Stephen E. Gist, M.D. Regarding Patient Carlos Vega, Erica Moore, Custodian of Records, 11/14/19 Affidavit of Records Custodian of MetroCare Regarding Patient Carlos Vega, Shea Abraham, Custodian of Records, 09/11/19 Correspondence-Witherite Law Group, Casey E. Kummell, 05/01/20 Plaintiff’s Sixth Supplemental Rule 194 Disclosure, 05/01/20 Medical Records Affidavit, of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega, Kusha Josef, Custodian of Records, 05/01/20 Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela Rosales, Custodian of Records, 05/01/20 Color Photo Texas ID Card, Carlos Vega, Iss: 01/17/15 Exp: 10/24/19 Medical Records Affidavit, of Prime Diagnostic Imaging, Regarding Patient Carlos Vega, Yasmine Garcia, Custodian of Records, 04/29/20 Affidavit of Records Custodian of Elevate Health Clinics, LLC, Regarding Patient Carlos Vega, Kusha Josef, Custodian of Records, 05/01/20 Affidavit of Records Custodian of JTP Diagnostics, LLC, Regarding Patient Carlos Vega, Yasmine Garcia, Custodian of Records, 04/29/20 Affidavit of Records Custodian of Uptown Radiology Associates Regarding Patient Carlos Vega, Karma Fernandez, Custodian of Records, 04/29/20 Radiology Records Affidavit of Prime Diagnostic Imaging Regarding Patient Carlos Vega, Yasmine Garcia, Custodian of Records, 04/29/20 Plaintiff’s Third Supplemental Rule 194 Disclosure, 11/20/19 Plaintiff’s Second Supplemental Rule 194 Disclosure, 10/25/19 Medical Records Affidavit, of Elevate Health Clinics, Regarding Patient Carlos Vega, Kusha Josef, Custodian of Medical Records, 10/10/19 Medical Records Affidavit, of Momentum Spine & Joint, Regarding Patient Carlos Vega, Tamela Rosales, Custodian of Medical Records, 10/04/19Medical Records Affidavit, of MRI Centers of Texas, Regarding Patient Carlos Vega, Adriana Ledesma, Custodian of Medical Records, 10/11/19 Affidavit of Records Custodian of Elevate Health Clinics, LLC-Dallas, Regarding Patient Carlos Vega, Kusha Josef, Custodian of Records, 10/10/19 Affidavit of Records Custodian of Momentum Spine & Joint Regarding Patient Carlos Vega, Tamela Rosales, Custodian of Records, 10/04/19 Affidavit of Records Custodian of MRI Centers of Texas, Regarding Patient Carlos Vega, Adriana Ledesma, Custodian of Records, 10/11/19 Radiology Records Affidavit of MRI Centers of Texas Regarding Patient Carlos Vega, Adriana Ledesma, Custodian of Records, 10/11/19 Plaintiff’s First Supplemental Rule 194 Disclosure, 09/09/19 Radiology Records Affidavit of Baylor University Medical Center Regarding Patient Carlos Vega, Samuel Malhew, Custodian of Records, 05/22/19 Color Photographs, 4-Pages, 00/00/00 Itemized Statement, JTP Diagnostics, LLC, Statement Date: 01/28/19, Date of Service: 03/06/18 Carlos Vega August 18, 2020 CASE #: 21182707 Page 7 of 9 Itemized Statement, Momentum Spine & Joint, Statement Date: 02/07/19, Date of Service: 02/22/18- 03/12/18 Health Insurance Claim Form, Momentum Spine & Joint, 02/22/18, (99203) Health Insurance Claim Form, Momentum Spine & Joint, 03/12/18, (9 9213) Estimated Bill of Services, Momentum Spine & Joint, 00/00/00 Itemized Statement, American Radiology Consultants, , Statement Date: 02/02/19, Date of Service: 02/06/18 Itemized Statement, Baylor University Medical Center, Statement Date: 03/19/18, Date of Service: 02/06/18-03/10/18 Patient Account Ledger, Baylor University Medical Center, Ledger Date: 03/20/18, Date of Service: 02/06/18 Patient Account Ledger, Buckner Pain and Injury, Ledger Date: 06/29/18, Date of Service: 02/08/18- 04/24/18 Health Insurance Claim Form, Buckner Pain and Injury, 02/08/18 (A4556); 02/08/18 (99080); 02/08/18 (99203); 02/08/18 (97014); 02/08/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 02/08/18 (97010); 02/08/18 (97140); 02/08/18 (97035); 02/09/18 (97014); 02/09/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 02/09/18 (97010); 02/09/18 (97140); 02/09/18 (97035); 02/12/18 (97014); 02/12/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 02/12/18 (97010); 02/12/18 (97140); 02/12/18 (97035); 02/13/18 (97014); 02/13/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 02/13/18 (97010); 02/13/18 (97140); 02/13/18 (97035); 02/14/18 (97014); 02/14/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 02/14/18 (97010); 02/14/18 (97140); 02/14/18 (97035); 02/14/18 (97110); 02/14/18 (97014) Health Insurance Claim Form, Buckner Pain and Injury, 02/15/18 (97012); 02/15/18 (97010); 02/15/18 (97140); 02/15/18 (97035); 02/15/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 02/16/18 (97014); 02/16/18 (97012); 02/16/18 (97010); 02/16/18 (97035) Health Insurance Claim Form, Buckner Pain and Injury, 02/16/18 (97110); 02/19/18 (97014); 02/19/18 (97012); 02/19/18 (97010); 02/19/18 (97140) Health Insurance Claim Form, Buckner Pain and Injury, 02/19/18 (97035); 02/19/18 (97110); 02/20/18 (97014); 02/20/18 (97012); 02/20/18 (97010) Health Insurance Claim Form, Buckner Pain and Injury, 02/20/18 (97140); 02/20/18 (97035); 02/20/18 (97110); 02/21/18 (99213); 02/21/18 (97014) Health Insurance Claim Form, Buckner Pain and Injury, 02/21/18 (97012); 02/21/18 (97010); 02/21/18 (97140); 02/21/18 (97035); 02/21/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 02/27/18 (97014); 02/27/18 (97012); 02/27/18 (97140); 02/27/18 (97035); 02/27/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 02/28/18 (97014); 02/28/18 (97012); 02/28/18 (97140); 02/28/18 (97035); 02/28/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/03/18 (97014); 03/03/18 (97012); 03/03/18 (97140); 03/03/18 (97035); 03/03/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/05/18 (97014); 03/05/18 (97012); 03/05/18 (97140); 03/05/18 (97035); 03/05/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/06/18 (97014); 03/06/18 (97012); 03/06/18 (97140); 03/06/18 (97035); 03/06/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/09/18 (97014); 03/09/18 (97012); 03/09/18 (97140); 03/09/18 (97035); 03/09/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/12/18 (97014); 03/12/18 (97012); 03/12/18 (97140); 03/12/18 (97035); 03/12/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/13/18 (97014); 03/13/18 (97012); 03/13/18 (97140); 03/13/18 (97035); 03/13/18 (97110) Carlos Vega August 18, 2020 CASE #: 21182707 Page 8 of 9 Health Insurance Claim Form, Buckner Pain and Injury, 03/19/18 (97012); 03/19/18 (97140); 03/19/18 (97035); 03/19/18 (97110); 03/21/18 (99213) Health Insurance Claim Form, Buckner Pain and Injury, 03/21/18 (97014); 03/21/18 (97012); 03/21/18 (97140); 03/21/18 (97035); 03/21/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/27/18 (97014); 03/27/18 (97012); 03/27/18 (97140); 03/27/18 (97035); 03/27/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 03/28/18 (97014); 03/28/18 (97012); 03/28/18 (97140); 03/28/18 (97035); 03/28/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 04/05/18 (97014); 04/05/18 (97012); 04/05/18 (97140); 04/05/18 (97035); 04/05/18 (97110) Health Insurance Claim Form, Buckner Pain and Injury, 04/09/18 (97012); 04/09/18 (97140); 04/09/18 (97035); 04/09/18 (97110); 04/24/18 (97012) Health Insurance Claim Form, Buckner Pain and Injury, 04/24/18 (97140); 04/24/18 (97110); 04/24/18 (99080) Health Insurance Claim Form, Baylor University Medical Center, 02/06/18 Itemized Statement, City of Dallas, Statement Date: 02/20/20, Date of Service: 02/06/18 Itemized Statement, Coast to Coast Radiology Consulting, Statement Date: 02/25/18, Date of Service: 02/12/18 Patient Ledger-DFW Diagnostics, Unidentified, M.D., Ledger Date: 03/17/18, Date of Service: 02/09/18 Health Insurance Claim Form, DFW Diagnostics, 02/09/18, (72050); 02/09/18, (72070); 02/09/18, (72100) Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Billing Review, Dallas Fire-Rescue, Dustin Mobley, Paramedic, Review Date: 02/06/18, Date of Service: 02/06/18 Patient Account History, Behavioral Health Providers, Summary Date: 10/08/19, Date of Service: 10/08/19 Health Insurance Claim Form, Behavioral Health Providers, 10/08/19, (9 6 1 1 6); 10/08/19, (96121); 10/08/19, (96138); 10/08/19, (96139); 10/08/19, (96132); 10/08/19, (96133) Itemized Statement, Elevate HC Texas, Statement Date: 11/20/19, Date of Service: 09/09/19-11/11/19 Health Insurance Claim Form, Elevate HC Texas, 09/09/19, (95816) Health Insurance Claim Form, Elevate HC Texas, 09/09/19, (99204) Health Insurance Claim Form, Elevate HC Texas, 09/23/19, (92015) Health Insurance Claim Form, Elevate HC Texas, 09/23/19, (92004) Health Insurance Claim Form, Elevate HC Texas, 10/10/19, (99214) Health Insurance Claim Form, Elevate HC Texas, 10/14/19, (96138) Health Insurance Claim Form, Elevate HC Texas, 10/14/19, (92523) Patient Account History, Injury 1 Dallas, Summary Date: 09/11/19, Date of Service: 03/08/11-11/14/19 Health Insurance Claim Form, Medical Specialists Associated, 09/19/19 (9 9 2 1 3); 09/19/19 (92552) Patient Ledger-MetroCare Services, Unidentified, M.D., Ledger Date: 09/11/19, Date of Service: 12/12/18-07/31/19 Itemized Statement, MetroCare Services, Statement Date: 09/11/19, Date of Service: 02/06/18- 12/01/18 Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Itemized Statement, Elevate HC Texas, Statement Date: 05/01/20, Date of Service: 09/09/19-04/28/20 Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92537) Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92547) Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92540) Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92507) Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (92546) Health Insurance Claim Form, Elevate HC Texas, 11/11/19, (99213) Carlos Vega August 18, 2020 CASE #: 21182707 Page 9 of 9 Health Insurance Claim Form, Elevate HC Texas, 12/10/19, (92507) Health Insurance Claim Form, Elevate HC Texas, 12/10/19, (99213) Health Insurance Claim Form, Elevate HC Texas, 12/17/19, (92507) Health Insurance Claim Form, Elevate HC Texas, 12/31/19, (92507) Health Insurance Claim Form, Elevate HC Texas, 01/28/20, (92507) Health Insurance Claim Form, Elevate HC Texas, 02/11/20, (92507) Health Insurance Claim Form, Elevate HC Texas, 03/09/20, (92507) Health Insurance Claim Form, Elevate HC Texas, 03/09/20, (99215) Health Insurance Claim Form, Elevate HC Texas, 04/10/20, (92507) Health Insurance Claim Form, Elevate HC Texas, 04/28/20, (99214) Itemized Statement, JTP Diagnostics, Statement Date: 04/29/20, Date of Service: 03/06/18-04/22/20 Itemized Statement, Momentum Spine & Joint, Statement Date: 04/29/20, Date of Service: 02/22/18- 04/07/20 Health Insurance Claim Form, Momentum Spine & Joint, 07/16/19, (9 9 2 1 3) Health Insurance Claim Form, Momentum Spine &Joint, 08/15/19, (99213) Health Insurance Claim Form, Momentum Spine &Joint, 08/15/19, (64483); 08/15/19, (20605); 08/15/19, (77002) Health Insurance Claim Form, Momentum Spine & Joint, 09/05/19, (9 9 2 1 3) Health Insurance Claim Form, Momentum Spine & Joint, 12/20/19, (9 9 2 1 3) Health Insurance Claim Form, Momentum Spine & Joint, 01/15/20, (64483) Health Insurance Claim Form, Momentum Spine & Joint, 02/03/20, (9 9 2 1 2) Health Insurance Claim Form, Momentum Spine & Joint, 04/07/20, (9 9 2 1 4) Itemized Statement, Uptown Radiology Associates, Statement Date: 04/29/20, Date of Service: 09/30/19 Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Itemized Statement, Uptown Radiology Associates, Statement Date: 10/23/19, Date of Service: 09/30/19 Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Estimated Bill of Services-Lumbar transforaminal epidural steroid injection,L5-S1, Momentum Spine & Joint, 00/00/00 Estimated Bill of Services-Momentum Spine & Joint, Right Elbow Injection, Unidentified, M.D., Estimate Date: 00/00/00 Itemized Statement, Elevate HC Texas, Statement Date: 10/09/19, Date of Service: 09/09/19 Itemized Statement, Momentum Spine & Joint, Statement Date: 09/23/19, Date of Service: 02/22/18- 09/05/19 Health Insurance Claim Form, MRI Centers of Texas, 09/30/19, (70551) Patient Ledger-MRI Centers of Texas, Unidentified, M.D., Ledger Date: 00/00/00, Date of Service: 09/30/19 Exhibit C (Paid Plus Still Owed), Multiple Accounts-Unidentified, M.D., Statement Date: 00/00/00, Date of Service: 00/00/00 Professional Experience I MIND Headache and Neurology PLLC Treat and manage patients with neurological disorders in an outpatient and inpatient setting. Experienced in treating various diseases such as multiple sclerosis, acute stroke, seizures, neuropathy, migraines, back pain, dementia, traumatic brain injury, and Parkinson’s disease. Proficient in reading and interpreting EEGs. Proficient in concussion diagnosis and management CEO/Neuro/ogist- January 201 7- Present Veterans Evaluation Services- Evaluate veterans with suspected traumatic brain injury and other service connected neurological conditions. 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Chad Kimble Bar No. 24007483 eservice@chadkimblelaw.com Envelope ID: 45846327 Status as of 9/1/2020 2:59 PM CST Associated Case Party: CARLOS VEGA Name BarNumber Email TimestampSubmitted Status Jibraeel Zaidi Jib.Zaidi@witheritelaw.com 8/31/2020 3:51 :54 PM SENT Christal Bables Christal.bables@witheritelaw.com 8/31/2020 3:51 :54 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Gaby Velasquez gabyv@diazlf.com 8/31/2020 3:51 :54 PM SENT Associated Case Party: JOSEFINA VAZQUEZ Name BarNumber Email TimestampSubmitted Status Kyle Smith eservice@chadkimblelaw.com 8/31/2020 3:51 :54 PM SENT