On August 17, 2017 a
Party Statement
was filed
involving a dispute between
Downie-Fraser, Nicole E.,
and
Sainz, Valeria,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
DALLAS COUNT
9/27/2017 12:34 PM
FELICIA PITRE
DISTRICT CLER
CAUSE NO. DC-1 7-1 0220
NICOLE E. DOWNlE-FRASER, IN THE DISTRICT COURT
Plaintiff,
v. 95th JUDICIAL DISTRICT
VALERIA SAINZ,
Defendant. DALLAS COUNTY, TEXAS
COST 0F SERVICES AFFIDAVIT 0F NORTH TEXAS OPEN AIR MRI
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff Nicole Eugene Downie-Fraser files the attached Cost of Services Affidavit
of North Texas Open Air MRI in accordance with section 18.001, et seq. of the Texas
Civil Practices & Remedies Code.
Respectfully submitted,
/s/ Cameron Dean
Cameron Dean
State Bar No. 2408291 0
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(81 7) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE 0F SERVICE
This is to certify that a true and correct copy of the foregoing document was served
on all counsel of record and/or pro se parties in accordance with Rules 21 and 21a of
the Texas Rules of Civil Procedure on this fl day of September, 20H.
/s/ Cameron Dean
Cameron Dean
COST OF SERVICES AFFIDAVIT OF NORTH TEXAS OPEN AIR MRI Page 6
) Cause No.:
)
)
Plaintiff, ) IN THE DISTRICT IN AND FOR COUNTY,
) TEXAS
VS .
)
)
)
)
Defendant )
AFFIDAVIT OF NECESSITY OF SERVICES/REASONABLENESS OF CHARGES
Before me, the undersigned authority, on this day personally appeared DR. LOU
SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making
this affidavit, and personally acquainted with the facts herein stated:
10
I am the custodian of billing records for NORTH TEXAS OPEN AIR MRI. Attached
hereto are billing records from 09/17/2016, pertaining to NICOLE FRASER, DOB:
ll 03/23/1970, SSN: N/A. These pages of billing records are kept by NORTH TEXAS
OPEN AIR MRI, in the regular course of business, and it was the regular
12 course of business of NORTH TEXAS OPEN AIR MRI, for an employee or
representative of NORTH TEXAS OPEN AIR MRI, with knowledge of the act, event,
13 condition, opinion, or diagnoses recorded to make the record or to transmit
information thereof to be included in such record and the record was made at
or near the time or reasonably after the time that the service was provided.
14
The total cost of services for NICOLE FRASER received at this facility is
15 $5,913.00 (which may include a Records Summary Report fee of $150.00). The
total amount adjusted, payments, and write off is $0.00. The adjusted total
l6 cost reflects billing and adjustment as of the data of this affidavit. With
the sole exception of fees related to the Records Summary Report fee of
17 $150.00, these services and charges were both reasonable and necessary in
connection with NICOLE FRASER treatment. The amount currently unpaid but
which NORTH TEXAS OPEN AIR MRI has a right to be paid after any adjustments
18
or credits is $5,913.00.
19 I am familiar with the charges rendered in the vicinity in which they were
incurred. I consider these charges to be reasonable and customary for all
20 like or similar services. The records attached hereto are the original or
exact duplicates of the original.
21
Affiant
22
swomq Io AND SUBSCRIBED before me on the M) day of L;
{A '
f
, 2017.
23
24
Bwqrame/mm
Notaz‘y Public, State of Texas:
Notary's printed name and
25 commission expires:05—13—2019
mt
LJLV LOUISE SAlINAs ':
Notaty Publrc. State o! Texas '1
._
-'
Mv Commission Expises
fizfinm M0v13‘2019
Document Filed Date
September 27, 2017
Case Filing Date
August 17, 2017
Category
MOTOR VEHICLE ACCIDENT
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FILED DALLAS COUNT 9/27/2017 12:34 PM FELICIA PITRE DISTRICT CLER CAUSE NO. DC-1 7-1 0220 NICOLE E. DOWNlE-FRASER, IN THE DISTRICT COURT Plaintiff, v. 95th JUDICIAL DISTRICT VALERIA SAINZ, Defendant. DALLAS COUNTY, TEXAS COST 0F SERVICES AFFIDAVIT 0F NORTH TEXAS OPEN AIR MRI TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff Nicole Eugene Downie-Fraser files the attached Cost of Services Affidavit of North Texas Open Air MRI in accordance with section 18.001, et seq. of the Texas Civil Practices & Remedies Code. Respectfully submitted, /s/ Cameron Dean Cameron Dean State Bar No. 2408291 0 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (81 7) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF CERTIFICATE 0F SERVICE This is to certify that a true and correct copy of the foregoing document was served on all counsel of record and/or pro se parties in accordance with Rules 21 and 21a of the Texas Rules of Civil Procedure on this fl day of September, 20H. /s/ Cameron Dean Cameron Dean COST OF SERVICES AFFIDAVIT OF NORTH TEXAS OPEN AIR MRI Page 6 ) Cause No.: ) ) Plaintiff, ) IN THE DISTRICT IN AND FOR COUNTY, ) TEXAS VS . ) ) ) ) Defendant ) AFFIDAVIT OF NECESSITY OF SERVICES/REASONABLENESS OF CHARGES Before me, the undersigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: 10 I am the custodian of billing records for NORTH TEXAS OPEN AIR MRI. Attached hereto are billing records from 09/17/2016, pertaining to NICOLE FRASER, DOB: ll 03/23/1970, SSN: N/A. These pages of billing records are kept by NORTH TEXAS OPEN AIR MRI, in the regular course of business, and it was the regular 12 course of business of NORTH TEXAS OPEN AIR MRI, for an employee or representative of NORTH TEXAS OPEN AIR MRI, with knowledge of the act, event, 13 condition, opinion, or diagnoses recorded to make the record or to transmit information thereof to be included in such record and the record was made at or near the time or reasonably after the time that the service was provided. 14 The total cost of services for NICOLE FRASER received at this facility is 15 $5,913.00 (which may include a Records Summary Report fee of $150.00). The total amount adjusted, payments, and write off is $0.00. The adjusted total l6 cost reflects billing and adjustment as of the data of this affidavit. With the sole exception of fees related to the Records Summary Report fee of 17 $150.00, these services and charges were both reasonable and necessary in connection with NICOLE FRASER treatment. The amount currently unpaid but which NORTH TEXAS OPEN AIR MRI has a right to be paid after any adjustments 18 or credits is $5,913.00. 19 I am familiar with the charges rendered in the vicinity in which they were incurred. I consider these charges to be reasonable and customary for all 20 like or similar services. The records attached hereto are the original or exact duplicates of the original. 21 Affiant 22 swomq Io AND SUBSCRIBED before me on the M) day of L; {A ' f , 2017. 23 24 Bwqrame/mm Notaz‘y Public, State of Texas: Notary's printed name and 25 commission expires:05—13—2019 mt LJLV LOUISE SAlINAs ': Notaty Publrc. State o! Texas '1 ._ -' Mv Commission Expises fizfinm M0v13‘2019