Preview
FILED
DALLAS COUNTY
11/12/2019 7:23 PM
FELICIA PITRE
DISTRICT CLERK
Terri Kilgore
Contains Sensitive Data
CAUSE NO.
CAUSE N0. DC - IQ 4042.4:
RHODES
VASHONE RHODES §
§ IN COURT
IN THE DISTRICT COURT
§
v.
V. §
§
§ 160TH
160T}! JUDICIAL DISTRICT
§
§
JAMES GOMEZ
JAMES GOMEZ §
§
§
§
§
§ DALLAS COUNTY,
CQUNTY, TEXAS
DEFENDANT’S COUNTER-AFFIDAVIT PURSUANT TO
DEFENDANT'S To SECTION 18.001
18.001
TEXAS CIVIL PRACTICES &
0F THE TEXAS
OF & REMEDIES CODE
REMEDIES CODE
MEDICAL &
RE: MEDICAL
RE: & BILLING AFFIDAVITS
AFFIDAVI’I‘S
STATE OF
STATE TEXAS
0F TEXAS
KNOWN MEN BY
KNOWN ALL MEN BY THESE
PRESENTS:
PRESENTS:
«
‘
COUNTY OF
COUNTS' DALLAS
0F DALLAS -
~ .
BEFORE ME,
ME, the
the undersigned
undersigned authority,
authority, a
a notary public in and for
for the
thc Stale
State of
of Texas,
Texas,
on this
this day
day personally
personally appeared Lennard A.
A. Nadalo,
Nadalo, M.D., F.A.C.R. who
M.D., F.A.C.R. who being
being by mc first
by me first
duly
duly sworn upon his oath,
oath. deposed as
us slated;
slated:
"My
“My name is
is Lennard
Lennard A.
A. Nadalo,
Nadalo, M.D.,
M.D., F.A.C.R.
F.A.C.R.’ I am a licensed
licensed Medical
I Medical Doctor
Doctor in
in
Texas and
and Illinois,
Illinois. I am an ABR Board Certified
I Certified Radiologist.
Radiologist. I also
also hold
hold special
special certification
I certification in
in
Neuroradiology granted
Ncuroradiology granted me
mc by
by the
the American
American Board
Board of
of Radiology.
Radiology. I have
have a
a BS Summa cum
BS Summa
I cum laude
laude
from
from North
North Park
Park University,
University, Chicago,
Chicago, Illinois
Illinois and
and a
a M.D. with Honors
M.D. with Honors in
in Pathology
Pathology and
and Clinical
Clinical
Diagnosis
Diagnosis from
from Northwestern
Northwestern University,
University, Chicago,
Chicago, Illinois.
Illinois. I currently practice Diagnostic
currently practice
I Diagnostic
Radiology
Radiology and
and Neuroradiology
Neuroradiology in
in Methodist Dallas Medical Center,
Center, Methodist
Methodist Charlton
Charlton Medical
Medical
Center,
Center, Methodist McKinney Hospital,
Hospital, Crescent Medical Center Lancaster,
Lancaster, First
First Baptist Medical
Baptist Medical
Center
Center and Very Special
and Very Special Images,
Images, PLLC.
PLLC. I am currently
currently on the Methodist
I Methodist Dallas Medical
Medical Center
Center
and Methodist Charlton Medical Center Tumor Board. fellowship in
Board. 1I also have a fellowship in the American
the American
College
College of
0f Radiology,
Radiology, F.A.C.R.
F.A.C.R. (Sec
(Scc Curriculum Vitae,
Vituc, attached hereto
hereto as Exhibit 'A.‘
as Exhibit A.'
incorporated
incorporated herein
herein for
for all
all purpo.ses.)
purposes.) 1 am over
over 18
I years ol
l8 years 0f age,
age, of
of sound
sound mind,
mind, and make this
and make this
affidavit
affidavit upon
upon my best
best information
information and belief.
bclicf. I state that I
state
I that am
I qualified by knowledge, skill,
qualified knowledge, skill,
experience,
experience, training,
training, education
education and other
other expertise
expertise to
to make thethe statements
statements contained
contained in
in this
this
affidavit
affidavit and
and II am fully
fully competent to
to testify
testify to
to the matters
matters stated herein.
herein. My Texas license
license is
is
E5417.
E5417. I have treated
I treated numerous patients
patients inin the
thc field
field of diagnostic radiology.
radiology. I practice
practice l
Diagnostic
Diagnostic Radiology
Radiology and Neuroradiology
Ncuroradiology in in multiple hospitals including a hospital
hospital serving
serving aa
trauma
trauma center.
ccntcr. I have
have performed
I performed numerous record reviews and served as an expert witness witness for
for
both
both plaintiffs
plaintiffs and defendants
defendants in
in Dallas
Dallas County,
County. Collin
Collin County,
County, Tarrant
Tarrant County and
and throughout
throughout
the
the State
State of Texas.
Texas. I am familiar
familiar with reasonable and customary charges
I charges for
for evaluation and
evaluation and
treatment
treatment thereof in Dallas County and throughout the Stale of Texas."
thereofin throughout the Stale ol'Tcxz-xs.”
COUNTER-AFFIDAVIT OF
()F Lennard A.
A. Nadalo, M D. FACR
Nadalo. MD, Page 1l
I'age
10001.14942/emonsivai.-i
I000! l494216m0nsivais
.
"This
“This countcr-ynidavil
countcr-affidavil is
is made pursuant to
lo §18.001
§IS.001 of
0f the TnXAS
TEXAS Civil
CIVIL PRACTlcns
PRACTICES & &
Rembpies
REMEDIES Code
CODE and is
is made in m the following
in response to mlluwing affidavits
affidavits and/or
andr’or records pertaining
pertaining to
to
‘B‘:
Rhodes which are attached hereto as Exhibit 'B':
Plaintiff Vashone Rhodes
MRI Centers of
1. MRI
l Texas;
ochxas;
2.
2. Dallas
Dallas Radiology;
Radiology;
3.
3. URA/Uptown Radiology Associates;
Associates; and
4.
4 Prinie
Prime Diagnostic
Diagnostic Imaging/Prime
Iluaging/Prime Imaging Partners.
Partners.
"Such
“Such affidavits
affidavits state
slate as
as a
a purported
purported fact
fact that
that the
the services outlined on attachments thereto
thereto
were necessary
were necessary and that
that the
the charges
charges for
for said
said services
services were reasonable;
reasonable; however,
however. I have reviewed
l
the
the medical and billing
billing records
records attached
attached toto the
the above-referenced affidavits
affidavits and it is
itis my opinion,
opinion,
based on my training,
training, experience,
experience, and expertise,
expertise, that
that the
thc health care treatment and numerous
procedures
procedures and charges,
charges, asas indicated
indicated in in my report
report dated
dated November 3. 3. 2019.
2019, are neither
reasonable,
reasonable, necessary
necessary nor justified by
norjustified by the condition as described by
the condition as described by said medical reports.
said medical reports. Please
see
see the
the true
true and correct
correct copy
copy of the
the report
report which is
is attached to this counter-affidavit and
attached 10 this countcr-affidavit
)9,
incorporated herein by
by reference as ‘C
as Exhibit 'C'." .
Further Affiant
Affiant sayetli
sayeth not.
not.
(4'ww/% 422M Azsz-flcaé;
Tcnnard
Lennard A.
A. Nadalo,
Nadaln, iVT.D.,
M.D., F.A.C.R.
F.A.C.R.
TEXAS
STATE OF TEXAS §
§
§
§
DALLAS
COUNTY OF DALLAS §
§
SWORN TO
SWORN AND SUBSCKIBLD
lU AND SUBSCRIBED before mc by
belore me by Lcnnard
l:)y A. Nadalo,
Lennard A. M.D.,
Nadalo, M.U., F.A.C.R.
F.A.C.R.. on
M.D., r.A.L
r\
’
is
this [df day
day of I O‘VCfil/lbfi’r , 2019,
,
2019, to
to certify witness my hand and
certify which witness
official
official seal.
seal.
I
/
\W /(/fl//V
0F RADIOLOGY
CUSTODIAN OF
SWORN TO AND SUBSCRIBED before
before me
me on
On the
the . E day of 21 M , 10 E;
.
g
'ITOTARY PUBLiIc Ira F0 THE STATE 0F TEXAS:
i IE
NOTARY's PHIWTED'NAME:
NOTARYS PfilgTE’gENAIEn/Iszfi I 2
i
MY COMMISSION EXPIRES:yuUiM)
MY COMMISSION EXPIRES:
I
o
g..-
Col .
'Notamo
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.
o'Texa«l
Exams 01-1 8.2020
i!!g£g'0i304Sii«.»°
130499333 ,
0F RECORDS
AFFIDAVIT OF
AEFIDAVET UETOWN RADIOLOGY ASSOCIATES
RECORDS CUSTODIAN OF UPTOWN
VASHONE RHODES
PATIENT VASHONE
REGARDING PATIENT RHODES
this
0F TEXAS
STATE OF
0F
COUNTY OF
TEXAS
who, being
who, being by
b.22—
n
§
§
§
BEFORE ME,the undersigned authority, personally appeared
BEFORE ME, the undersigned authority, personally appeared
by me duly
duly sworn,
sworn. deposed as follows:
Moi OMW
follows:
My name is PXailidrAA PgiiS
My name is
this Affidavit,
Affidavit, and personally
personally aatpalnted
1 am a custodian of
aoqdainted vwth
with the
the facts
-
facts herein
.
(
am
herein stated.
stated.
MM
I am of sound
I of
^
sound mind,
mind. capable
capable of
of making
making
I of records
records for
for Uptovm
Uptown Radiology
Radiology Associates.
Associates. Attached to to this
this Affidavit
Affidavit are
records that
that provide
provide an itemized statement of the service
itemized statement of the service and the charge for the
the charge for the service
service that
that Uptown
Radiology Associates provided to
to Vashone Rhodes on 11/27/2018
11/27I2018 to
to present.
present. The attached records
records are
are
a part
part of
of this
this afficlavit.
affidavit.
The attached
attached records
records are
are kept
kept by
by Uptown Radiology
Radiology Associates
Associates in
in the
the regular
regular course
counse of
of business,
business,
and it was
was the
it the regular
regular course
course ofof business
business of
of Uptown
Uptown Radiology
Radiology Associates
Associates forfor an
an employee
employee or or
representative
representative of
of Uptown
Uptown Radiology
Radiotogy Associates, w^h knowledge
Associates. with knowledge of
of the
the service
service provided,
provided. to
to make
make the
the
.
record or to
to transmit
transmit information
information to
to be inctuded
included in
in the
the record.
record. The records were made In
records were in the
the regular
regular
course of business at
at or
or near the
the time
time or
or reasonably
reasonably soon after
after the
the time
time the
the service was provided.
service was provided. The
records are the
the original
original or
or a
a duplicate
duplicate of
of the
the original.
original.
The services
services provided
provided were necessary
necessary and the
the amount charged
chewed for
for the
the service
service was reasonable
reasonable
at
at the
the time
time and place that the services were provided.
place that the services were provided.
The total
total amount paid
paid for
for the services was $g
the sen/Ices and the
the amount currently
currently unpaid but
which Uitmown Radiology Associates has a
a right
right be paid after
after any adjustments or credits
credits is
is
$
mm (Mm
CUSTODIAN OF
CUSTODIA^^I 0E5 BILLING RECORDS
SWORN
SWORN TO
To AND
AND SUBSCRIBED before me
SUBSCRIBED before me on
on the
the _ ^day
day of
arm?!" . 20
20M .
MBUC STATE OF TEXAS:
W
NOTARY PUBLIC IN AND FOR THE STATE TEXAS:
_ A“ A A
§ng
^;P/'T*%&Notarv
LORl
Loni
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MAWHAM
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Public. Stats
State of TskbsI
Texas
'
Engflsgé' Comm.
Comm. Expires 02-OZ-2Q22
02-02-2022 NOTARY'S PRINTED
PRINTED NAME:
NAME:
^11%^
”Ia.3§“s~\“ NotBfY
Nomy IDID 131434483
131434483
MYCOMMISSION
MY EXPIRES;
COMMISSION EXPIRES 2! ‘9':
RECORDS CUSTODIAN OF DALLAS
AFFIDAVIT OF RECORDS RADIOLOGY PA.
DALLAS RADIOLOGY. PA.
REGARD NG PATIENT
REGARDING PATIENT VASHQNE RHODES
VASHONE RHODES
0F TEXAS
STATE OF §
§
7^ §
COUNTY
COUNTY OF
0F iMiks
24/155 Ig
BEFORE
BEFORE ME.the undersigned authority, personally appeared /4m.
who, being by
ME, the undersigned authority. personally
me duly sworn, deposed as follows:
fl /lA
M W131
appeared [t
l2
who. by me dulysworn. deposed as follows:
this
My
My name
name is
this Affidavit,
is A71“
Affidavit. and personally
personally
m W“?
/H WoZ
p-
acquainted
acquainted with
with the
the facts
facts herein
herein
^ I am of
stated.
stated.
of sound
. sound
I mind,
mind, capable
capable of
of making
making
I am a custodian of
l of records
records for
for Dallas
Dallas Radiology,
Radiology. P.A..
P.A.. Attached toto this
this Affidavit
Affidavit are records thatthat
provide an itemized
itemized statement
statement of
of the
the service
service and
and the
the charge
charge for
for the
the service
service that
that Dallas
Dallas Radiology,
Radiology. P.A.
P.A.
provided to
to Vashone Rhodes on 11/27/2018
11/27/2018 toto present.
present. The attached
attached records
records are
are a part
part of
of this
this affidavit.
affidavit.
The attached records
records are
are kept
kept by
by Dallas
DaIIas Radiology.
Radiology. P.A.
P.A. in
in the
the regular
regular course of
of business,
business. and itit
was the regular course of
was of business ofof Dallas
Dallas Radiology,
Radiology. P.A.
P.A. for
for an employee or representative of Dallas
Radiology,
Radiology, P.A., with knowledge
P.A.. with knowledge of of the
the service
service provid^,
provided, to
to make the
the record
record or
or to
to transmit
transmit information
information to
to
be included inin the record.
record. The records were made in in the regular course of business at or near the time
or
or reasonably soon after
afier the time
time the
the service
service was provided.
provided. The records are the original
original or a duplicate of
W
the original.
original.
The services
services provided were necessary
necessary and the amount charged for
Preview
FILED DALLAS COUNTY 11/12/2019 7:23 PM FELICIA PITRE DISTRICT CLERK Terri Kilgore Contains Sensitive Data CAUSE NO. CAUSE N0. DC - IQ 4042.4: RHODES VASHONE RHODES § § IN COURT IN THE DISTRICT COURT § v. V. § § § 160TH 160T}! JUDICIAL DISTRICT § § JAMES GOMEZ JAMES GOMEZ § § § § § § DALLAS COUNTY, CQUNTY, TEXAS DEFENDANT’S COUNTER-AFFIDAVIT PURSUANT TO DEFENDANT'S To SECTION 18.001 18.001 TEXAS CIVIL PRACTICES & 0F THE TEXAS OF & REMEDIES CODE REMEDIES CODE MEDICAL & RE: MEDICAL RE: & BILLING AFFIDAVITS AFFIDAVI’I‘S STATE OF STATE TEXAS 0F TEXAS KNOWN MEN BY KNOWN ALL MEN BY THESE PRESENTS: PRESENTS: « ‘ COUNTY OF COUNTS' DALLAS 0F DALLAS - ~ . BEFORE ME, ME, the the undersigned undersigned authority, authority, a a notary public in and for for the thc Stale State of of Texas, Texas, on this this day day personally personally appeared Lennard A. A. Nadalo, Nadalo, M.D., F.A.C.R. who M.D., F.A.C.R. who being being by mc first by me first duly duly sworn upon his oath, oath. deposed as us slated; slated: "My “My name is is Lennard Lennard A. A. Nadalo, Nadalo, M.D., M.D., F.A.C.R. F.A.C.R.’ I am a licensed licensed Medical I Medical Doctor Doctor in in Texas and and Illinois, Illinois. I am an ABR Board Certified I Certified Radiologist. Radiologist. I also also hold hold special special certification I certification in in Neuroradiology granted Ncuroradiology granted me mc by by the the American American Board Board of of Radiology. Radiology. I have have a a BS Summa cum BS Summa I cum laude laude from from North North Park Park University, University, Chicago, Chicago, Illinois Illinois and and a a M.D. with Honors M.D. with Honors in in Pathology Pathology and and Clinical Clinical Diagnosis Diagnosis from from Northwestern Northwestern University, University, Chicago, Chicago, Illinois. Illinois. I currently practice Diagnostic currently practice I Diagnostic Radiology Radiology and and Neuroradiology Neuroradiology in in Methodist Dallas Medical Center, Center, Methodist Methodist Charlton Charlton Medical Medical Center, Center, Methodist McKinney Hospital, Hospital, Crescent Medical Center Lancaster, Lancaster, First First Baptist Medical Baptist Medical Center Center and Very Special and Very Special Images, Images, PLLC. PLLC. I am currently currently on the Methodist I Methodist Dallas Medical Medical Center Center and Methodist Charlton Medical Center Tumor Board. fellowship in Board. 1I also have a fellowship in the American the American College College of 0f Radiology, Radiology, F.A.C.R. F.A.C.R. (Sec (Scc Curriculum Vitae, Vituc, attached hereto hereto as Exhibit 'A.‘ as Exhibit A.' incorporated incorporated herein herein for for all all purpo.ses.) purposes.) 1 am over over 18 I years ol l8 years 0f age, age, of of sound sound mind, mind, and make this and make this affidavit affidavit upon upon my best best information information and belief. bclicf. I state that I state I that am I qualified by knowledge, skill, qualified knowledge, skill, experience, experience, training, training, education education and other other expertise expertise to to make thethe statements statements contained contained in in this this affidavit affidavit and and II am fully fully competent to to testify testify to to the matters matters stated herein. herein. My Texas license license is is E5417. E5417. I have treated I treated numerous patients patients inin the thc field field of diagnostic radiology. radiology. I practice practice l Diagnostic Diagnostic Radiology Radiology and Neuroradiology Ncuroradiology in in multiple hospitals including a hospital hospital serving serving aa trauma trauma center. ccntcr. I have have performed I performed numerous record reviews and served as an expert witness witness for for both both plaintiffs plaintiffs and defendants defendants in in Dallas Dallas County, County. Collin Collin County, County, Tarrant Tarrant County and and throughout throughout the the State State of Texas. Texas. I am familiar familiar with reasonable and customary charges I charges for for evaluation and evaluation and treatment treatment thereof in Dallas County and throughout the Stale of Texas." thereofin throughout the Stale ol'Tcxz-xs.” COUNTER-AFFIDAVIT OF ()F Lennard A. A. Nadalo, M D. FACR Nadalo. MD, Page 1l I'age 10001.14942/emonsivai.-i I000! l494216m0nsivais . "This “This countcr-ynidavil countcr-affidavil is is made pursuant to lo §18.001 §IS.001 of 0f the TnXAS TEXAS Civil CIVIL PRACTlcns PRACTICES & & Rembpies REMEDIES Code CODE and is is made in m the following in response to mlluwing affidavits affidavits and/or andr’or records pertaining pertaining to to ‘B‘: Rhodes which are attached hereto as Exhibit 'B': Plaintiff Vashone Rhodes MRI Centers of 1. MRI l Texas; ochxas; 2. 2. Dallas Dallas Radiology; Radiology; 3. 3. URA/Uptown Radiology Associates; Associates; and 4. 4 Prinie Prime Diagnostic Diagnostic Imaging/Prime Iluaging/Prime Imaging Partners. Partners. "Such “Such affidavits affidavits state slate as as a a purported purported fact fact that that the the services outlined on attachments thereto thereto were necessary were necessary and that that the the charges charges for for said said services services were reasonable; reasonable; however, however. I have reviewed l the the medical and billing billing records records attached attached toto the the above-referenced affidavits affidavits and it is itis my opinion, opinion, based on my training, training, experience, experience, and expertise, expertise, that that the thc health care treatment and numerous procedures procedures and charges, charges, asas indicated indicated in in my report report dated dated November 3. 3. 2019. 2019, are neither reasonable, reasonable, necessary necessary nor justified by norjustified by the condition as described by the condition as described by said medical reports. said medical reports. Please see see the the true true and correct correct copy copy of the the report report which is is attached to this counter-affidavit and attached 10 this countcr-affidavit )9, incorporated herein by by reference as ‘C as Exhibit 'C'." . Further Affiant Affiant sayetli sayeth not. not. (4'ww/% 422M Azsz-flcaé; Tcnnard Lennard A. A. Nadalo, Nadaln, iVT.D., M.D., F.A.C.R. F.A.C.R. TEXAS STATE OF TEXAS § § § § DALLAS COUNTY OF DALLAS § § SWORN TO SWORN AND SUBSCKIBLD lU AND SUBSCRIBED before mc by belore me by Lcnnard l:)y A. Nadalo, Lennard A. M.D., Nadalo, M.U., F.A.C.R. F.A.C.R.. on M.D., r.A.L r\ ’ is this [df day day of I O‘VCfil/lbfi’r , 2019, , 2019, to to certify witness my hand and certify which witness official official seal. seal. I / \W /(/fl//V 0F RADIOLOGY CUSTODIAN OF SWORN TO AND SUBSCRIBED before before me me on On the the . E day of 21 M , 10 E; . g 'ITOTARY PUBLiIc Ira F0 THE STATE 0F TEXAS: i IE NOTARY's PHIWTED'NAME: NOTARYS PfilgTE’gENAIEn/Iszfi I 2 i MY COMMISSION EXPIRES:yuUiM) MY COMMISSION EXPIRES: I o g..- Col . 'Notamo M . o'Texa«l Exams 01-1 8.2020 i!!g£g'0i304Sii«.»° 130499333 , 0F RECORDS AFFIDAVIT OF AEFIDAVET UETOWN RADIOLOGY ASSOCIATES RECORDS CUSTODIAN OF UPTOWN VASHONE RHODES PATIENT VASHONE REGARDING PATIENT RHODES this 0F TEXAS STATE OF 0F COUNTY OF TEXAS who, being who, being by b.22— n § § § BEFORE ME,the undersigned authority, personally appeared BEFORE ME, the undersigned authority, personally appeared by me duly duly sworn, sworn. deposed as follows: Moi OMW follows: My name is PXailidrAA PgiiS My name is this Affidavit, Affidavit, and personally personally aatpalnted 1 am a custodian of aoqdainted vwth with the the facts - facts herein . ( am herein stated. stated. MM I am of sound I of ^ sound mind, mind. capable capable of of making making I of records records for for Uptovm Uptown Radiology Radiology Associates. Associates. Attached to to this this Affidavit Affidavit are records that that provide provide an itemized statement of the service itemized statement of the service and the charge for the the charge for the service service that that Uptown Radiology Associates provided to to Vashone Rhodes on 11/27/2018 11/27I2018 to to present. present. The attached records records are are a part part of of this this afficlavit. affidavit. The attached attached records records are are kept kept by by Uptown Radiology Radiology Associates Associates in in the the regular regular course counse of of business, business, and it was was the it the regular regular course course ofof business business of of Uptown Uptown Radiology Radiology Associates Associates forfor an an employee employee or or representative representative of of Uptown Uptown Radiology Radiotogy Associates, w^h knowledge Associates. with knowledge of of the the service service provided, provided. to to make make the the . record or to to transmit transmit information information to to be inctuded included in in the the record. record. The records were made In records were in the the regular regular course of business at at or or near the the time time or or reasonably reasonably soon after after the the time time the the service was provided. service was provided. The records are the the original original or or a a duplicate duplicate of of the the original. original. The services services provided provided were necessary necessary and the the amount charged chewed for for the the service service was reasonable reasonable at at the the time time and place that the services were provided. place that the services were provided. The total total amount paid paid for for the services was $g the sen/Ices and the the amount currently currently unpaid but which Uitmown Radiology Associates has a a right right be paid after after any adjustments or credits credits is is $ mm (Mm CUSTODIAN OF CUSTODIA^^I 0E5 BILLING RECORDS SWORN SWORN TO To AND AND SUBSCRIBED before me SUBSCRIBED before me on on the the _ ^day day of arm?!" . 20 20M . MBUC STATE OF TEXAS: W NOTARY PUBLIC IN AND FOR THE STATE TEXAS: _ A“ A A §ng ^;P/'T*%&Notarv LORl Loni Publle. MAWHAM ot 1 ‘ Lb M \ ggifi‘g’?‘ Notary PubRc, Public. Stats State of TskbsI Texas ' Engflsgé' Comm. Comm. Expires 02-OZ-2Q22 02-02-2022 NOTARY'S PRINTED PRINTED NAME: NAME: ^11%^ ”Ia.3§“s~\“ NotBfY Nomy IDID 131434483 131434483 MYCOMMISSION MY EXPIRES; COMMISSION EXPIRES 2! ‘9': RECORDS CUSTODIAN OF DALLAS AFFIDAVIT OF RECORDS RADIOLOGY PA. DALLAS RADIOLOGY. PA. REGARD NG PATIENT REGARDING PATIENT VASHQNE RHODES VASHONE RHODES 0F TEXAS STATE OF § § 7^ § COUNTY COUNTY OF 0F iMiks 24/155 Ig BEFORE BEFORE ME.the undersigned authority, personally appeared /4m. who, being by ME, the undersigned authority. personally me duly sworn, deposed as follows: fl /lA M W131 appeared [t l2 who. by me dulysworn. deposed as follows: this My My name name is this Affidavit, is A71“ Affidavit. and personally personally m W“? /H WoZ p- acquainted acquainted with with the the facts facts herein herein ^ I am of stated. stated. of sound . sound I mind, mind, capable capable of of making making I am a custodian of l of records records for for Dallas Dallas Radiology, Radiology. P.A.. P.A.. Attached toto this this Affidavit Affidavit are records thatthat provide an itemized itemized statement statement of of the the service service and and the the charge charge for for the the service service that that Dallas Dallas Radiology, Radiology. P.A. P.A. provided to to Vashone Rhodes on 11/27/2018 11/27/2018 toto present. present. The attached attached records records are are a part part of of this this affidavit. affidavit. The attached records records are are kept kept by by Dallas DaIIas Radiology. Radiology. P.A. P.A. in in the the regular regular course of of business, business. and itit was the regular course of was of business ofof Dallas Dallas Radiology, Radiology. P.A. P.A. for for an employee or representative of Dallas Radiology, Radiology, P.A., with knowledge P.A.. with knowledge of of the the service service provid^, provided, to to make the the record record or or to to transmit transmit information information to to be included inin the record. record. The records were made in in the regular course of business at or near the time or or reasonably soon after afier the time time the the service service was provided. provided. The records are the original original or a duplicate of W the original. original. The services services provided were necessary necessary and the amount charged for