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  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
  • ALFONSO LARA  vs.  DAYAKAR PINDIMOTOR VEHICLE ACCIDENT document preview
						
                                

Preview

FILED 8/26/2020 11:54 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lafonda Sims DEPUTY Cause No. DC-19-13584 ALFONSO LARA § IN THE DISTRICT COURT Plaintiff, § § vs. § DALLAS COUNTY, TEXAS § § DAYAKAR PINDI § Defendant. § 160th JUDICIAL DISTRICT PLAINTIFF ALFONSO LARA’S NOTICE OF FILING RECORD AFFIDAVITS COMES NOW, ALFONSO LARA, and hereby files with the Court the following affidavits: Billing record affidavit of AMPM Medical Centers Medical record affidavit of AMPM Medical Centers Billing record affidavit of Cano Health & Rehab Medical record affidavit 0f Cano Health & Rehab Billing record affidavit of DFW MRI Medical record affidavit of DFW MRI Billing record affidavit of Epic Pain & Orthopedics Medical record affidavit of Epic Pain & Orthopedics Billing record affidavit of Lakewood Anesthesia Medical record affidavit 0f Lakewood Anesthesia Billing record affidavit 0f Radiology Consultants North Texas Medical record affidavit of Radiology Consultants North Texas Billing record affidavit of Singleton Associates, PA By copy of this Notice, opposing counsel are notified that these affidavits are being filed with the Court pursuant to TRE 902. The records corresponding to the enclosed affidavits will be kept in our office for use at trial. Copies 0f these affidavits and certified records were served on opposing counsel simultaneously on a CD containing Plaintiff s Rule 194 Disclosures Via certified mail return receipt requested, article number 91 7199 9991 7036 7648 5729. PLAINTIFF ALFONSO LARA’S NOTICE OF FILING RECORD AFFIDAVITS - Page 1 0f 2 Respectfully submitted, /s/ Sabrina L. Galvan Sabrina L. Galvan Texas Bar Number 24096871 Juan C. Hernandez Texas Bar Number 24002270 16850 Dallas Parkway Dallas, Texas 75248 sabrina@juanlaw.com (972) 235-4444 Telephone (972) 235-4454 Telecopy Attorneysfor Plaintifl CERTIFICATE OF SERVICE Ihereby certify that a true and correct copy 0f the foregoing instrument was forwarded to all attorneys of record in accordance with the Texas Rules 0f Civil Procedure, on this 26th day of August 2020. Via E-Service Scott A. Whitcomb Susan L. Florence & Associates 1201 Elm Street, Suite 5050 Dallas, Texas 75270 T: 214-659-4325 F: 877-678-4763 swhim@allstate.com Attorneyfor Defendant /s/ Sabrina L. Galvan SABRINA L. GALVAN PLAINTIFF ALFONSO LARA’S NOTICE OF FILING RECORD AFFIDAVITS - Page 2 0f 2 Cause No. DC-19-13584 ALFONSO LARA § IN THE DISTRICT COURT Plaintiff, § § vs. § DALLAS COUNTY, TEXAS § § DAYAKAR PINDI § Defendant. § 160th JUDICIAL DISTRICT AFFIDAVIT BY THTHE PERSON WHO IS IS IN CHARGE OF BILLING RECORDS (Affidavit (Affidavit per 18.001 et p r §§ 18.001, et seq. seq. of of the , the Civil Civil Practices Practices and and Remedies Remedies Code and ule 902(10) and lRule 902(10) b b of of the the Texas Texas Rules Rules of of Civil Civil Evidence) Evidence) BEFORE ME, the the imdersigned ndersigned authority, authority, personally personally appeared appeared g km “AV) @ruos <...XJ6o..3; [é mofi (name (name of of affiant), who, bei affiant), who, bei gg by by me duly duly sworn, sworn, deposed deposed as as follows: follows: My name is \b ‘.|/\ QmeDS (name of affiant). I am of sound mind and capable capable of making this this affi avit, and affijlavit, and am personally personally acquainted acquainted with the facts with the facts herein herein stated: stated: II am the the person person in in charge charge and and the the custodian custodian of of records of AMPM Medical records of Medical Centers. Centers. Attached Attached to this affidavit to this affidavit a e - - + - - pages ane pages of I billing records of billing records that provide an that provide an itemized itemized statement statement of of the the service service and and the the c arge for charge for the the service that AMPM Medical service that Medical Centers Centers provided provided to to A\Q’)fl®© ....!........l....!....L.!....L1-_i_,,_"' LEVI) -'-"'----==-"'---""'-+----- - --(name (name of patient) from ofpatient) //'J I ZQ’1 /J q q Z I [FIRST [FIRST DATE OF 0F SERVI E] through SERVICE] through JI(éh r ,Z /-J, / JMq [LAST DATE OF 0F SERVICE]. SERVICE]. The The attached attached billing billing records records ar are a part of a part of this this affidavit. affidavit. The total total charge charge for for the the services services provided provided is is /\DO S:2- 00 0 :gfio $ _ ____,-~" ' - - - - - - - - - + - - - - - l . The total total of of these charges that these charges that has has been been paid paid IS is $_ _ $ \S\ c9- ~------- . The total total of of these these charges charges that that are are still still owed IS is So oO oo $ $ ll. 960 The attached billi attached billing records records are kept by are kept by me in the regular in the regular course course of of business. business. The The information contained in th¢ billing records was transmitted to me in the regular course ofbusincss by AMPM Medical Centers or an employee or representative of AMPM Medical Centers who had personal knowledge of the information. The billing records were made at or near the time or reasonably soon afier the time that the service was provided. The billing records are the originals 0r an exact duplicate of the originals. The service providefi was necessary and the amount charged for the service was reasonable at the time and place that the service was provided. All statements made herein by me are within m a1 kno dge. SWORN TO AND SUBSC RIBED before me on the IQ day of KJL) l g 2019. \\\\\\H' IHl/l/II ‘ Ill, ’zt/ \\‘3“;%B§Afigrl4 (<24, S \RY Pg 2 sag. 2w 49;??? E m (5 ( m {a . Notary Publlc, State of Texas g z U“ W r”: é {gN E (>7. E w (T\-~ a 3, ?%Eor 3:593; ‘5 N t ’s printed name: ”’1’ " 8983'?“ s? OLVMM («67% ‘ '2’ 0’0,K): ' '21 \\\\\ ”’1' Imuun‘“ Cause No. DC-19-13584 ALFONSO LARA § IN THE DISTRICT COURT Plaintiff, § § vs. § DALLAS COUNTY, TEXAS § § DAYAKAR PINDI § Defendant. § 160th JUDICIAL DISTRICT AFFIDAVIT BY TH 4 PERSON WHO IS IS IN CHARGE OF MEDICAL RECORDS (Affidavit (Affidavit aa sper 18.001,, et per§§ 18.001 et seq. seq. of of the the Civil Civil Practice Practice & Remedies Remedies Code aa 1dd Rule Rule 902(10) 902(1 0) bb of of the the Texas Texas Rules Rules ofEvidence) of Evidence) BEFORE ME, the ndersigned authority, the mdersigned authority, personally appeared 1, )Clf)rv); n personally appeared rl JWI ~ OS park oS (name (name of of affiant), affiant), who, who, bei g by bei1 1g by me duly duly sworn, sworn, deposed deposed as as follows: follows: My name is 603 rwlm IZCm/uos (name of affiant). I am of sound mind and capable of capable of making this this affi avit, and affi+avit, and personally personally acquainted acquainted with the facts with the facts herein herein stated: stated: II am the the custodian custodian of of records records and and the the person person in in charge charge of of records of AMPM Medical records of Medical Centers. Centers. Attached Attached hereto hereto a e 3er k; (a pages pages of from AMPM Medical records from ofrecords Medical Centers Centers for for services services provided to t0 :. . . ; \. c:;.::,-::;:::= -.. .~oma .A A\£m$c I ----=-:...ri _V\ ____;__ (name (name of of patient) patient) from from l j;). \ / l~ I /Q\ ['0‘ to to _1_/~~~t. ./_. J_'i___ _ ( ates of services). let/I‘i r I (d ates of services). These These said said records records are are kept by AMPM Medical kept by Medical Centers Centers in in the regular cou the regular coul se se of business, and of business, and it it was the the regular regular course course of of AMPM business of of business Medical Medical Centers Centers for for an an em loyee or em] )loyee or representative of AMPM Medical representative of Medical Centers, Centers, with knowledge with knowledge of the act, of the act, event, event, conditio condition opinion, opinion, or or diagnosis, diagnosis, recorded , recorded to to make the the record record or to transmit or to transmit information information thereof to be thereof to be in luded in in :luded in such such record; record; and and the the record record was made at at or or near the time near the time of of the the act, act, event, event, condition, condition, opi ion, or opi aion, or diagnosis diagnosis recorded recorded or or reasonably reasonably soon soon thereafter. thereafter. The records records attached attached hereto hereto are are the the origi al or origi 1a] or exact exact duplicates duplicates of of the the original 011' ginal and and are part of are pan of this this affidavit. affidavit. The service provide was service provided necessary and was necessary and the the amount charged charged for for the the service service was reasonable reasonable at the time and place that e service was provided. A11 statements ma e herein by me are within my personal knowledge. AF .;v~ SWORN T0 AND SUBS RJBED before me on the / q day of u , 2019. 'll'! *tf: ”*3 \1‘ Q3?“ (1/! R J $$$$- -E. 74. 45% 3.3 i} 3 ".ng {$- ?gi 53‘ ‘5 ‘ ' ’56 vfiw ?— 7 L 3:: U 3 fir 3 Notary Public, State ofTexas Z : fig; .\K{E%; ‘ " ¥?éj‘ ii; a a ' 9;: Notary prmted name a ugfiks a s 4' ”ixzifigfl {lillii yEE‘3‘\\§ Mkfé ,N’e+fl [L5" w From: From: SLG Tum SL6 Team Fax: Fax: 12144425801 12144425801 To To:: 4695471404(!!)RCFaK.C0m 46954714040chxmom Fax: Fax: (469) (469) 547-1404 541-1404 Page: Pugo: 6 6 ol of 9 9 07/18/2019 D7I18I2019 9:37 9:37 AM Cause No. DC-19-13584 ALFONSO LARA § IN THE DISTRICT COURT Plaintiff, § § vs. § DALLAS COUNTY, TEXAS § § DAYAKAR PINDI § Defendant. § 160th JUDICIAL DISTRICT AFFIDAVIT BY THE PERSON WHO IS IS IN CHARGE OF 0F BILLING RECORDS (Affidavit (Affidavit per§ per § 18.00 1, et 18.001, et seq. seq. of the Civil ofthe Civil Practices Practices and Remedies Code Code and and Rule Rule 902(10) 902(10) b b of of the the Texas Texas Rules Rules of Civil Evidence) ofCivil Evidence) BEFORE ME, ME, the the undersigned undersigned authority, authority, personally personally appeared L1 na')i fl S“w Y ~{A IiW1“ Bs\1\~ 5R0! ‘ (name (name of of affiant), affiant), who, who, being by m being by mee duly duly sworn, swom, deposed as as follows: follows: My name is My is fu\11 \t~ sS:a \lflm‘: Afihmg Ovt..5(?flfl 1· (name (name of affiant). afliant). r am I of sound mind and capable capable of of making making this this affidavit, affidavit, and and am personally personally acquainted acquainted with with the the facts facts herein stated stated:: II am the the person in charge person in charge and and the the custodian custodian of records of Cano Health & Rehab. of records Attached to this Attached to this affidavit affidavit are are j_!!J__ 1i pages of billing records that provide an itemized statement pages ofbilling records that provide an itemized statement of of the the service service and and the the charge charge for for the the service service that Health & Rehab provided to that Cano Health to '[\ %h%o lut Y)“\ \'Ot\SO m (0\ (m (name (name of patient) from ofpatient) from Ii} ‘ Q k!\ $? if- · '):J-.- g [FIRST [FIRST DATE OF SERVICE) SERVICE] through through 4-tL. 4’27 --\ ’| °) I [LAST DATE OF SERVICE]. The attached attached billing billing records records are are a a part part of of thi thiss affidavit. affidavit. The total total charge charge for for the the services services provided is is oD $_ $ 1 ngu ~'----9___,,\_p__o 7.. .:. . .;,'---= _v_ _ _ . The The total total of of these these charges charges that that has has been been paid paid 1s is $_ ______,_, OO Q_oo _· _ _ _ $ O . The The total total of these charges of these that are charges that are still still owed 1s is $_ s mgmfm 1-+-- 1S~ 9.. J. . l.>-"".. octD_ _ _ The The attached attached billing billing records records are are kept kept by by me in in the the regular regular course course of of business. business. The From: SLG Team Fax: 12144425301 To: 46954714D4@RCF3K.c0m Fax: (469) 547-1404 Pago: T of 9 0711812019 9:37 RM information contained in the billing records was transmitted to me in the regular course of business by Cano Health & Rehab or an employee or representative of Cano Health & Rehab who had personal knowledge of the information. The billing records were made at or near the time or reasonably soon afier the time that the service was provided. The billing records are‘the originals or an exact duplicate of the originals. The service provided was necessmy and the amount charged for the service was reasonable at the time and place that the service was provided. A11 statements made herein by me are within my ersonal knowledge AFFIANT SWORN TO AND SUBSCRIBED before me on the l 3 l g day of A (J fi 0 3 Z 2019. ' Notary Pub tate of Texas 4 Notary’s printed name' fiyugg chéa flatly HERNAN ROCHA PADILLA Notary ID #1 30006759 My Commission Expires October 28, 2022 To: Page: Pago: 8 I of of 9 07/18/2019 9:37 AM