Preview
FILED
7/20/2020 10:47 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Miranda Lynch DEPUTY
CAUSE NO. DC-1 9-1 0926
VASHONE RHODES; § IN THE DISTRICT COURT OF
Plaintiff, g
VS. g DALLAS COUNTY, TEXAS
JAMES GOMEZ; g
Defendant. g 160th JUDICIAL DISTRICT
PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS
AND CERTIFIED COPIES
Plaintiff Vashone Rhodes files with the Court the attached record affidavits
and certified copies:
STATE RECORDS:
Defendant’s Certified Driving Record
MEDICAL RECORDS AFFIDAVITS:
MDN, PA dated 08/26/2019
MRI Centers of Texas dated 08/05/201 9
Orthopaedic & Spine Specialists of Texas, LLC dated 08/22/2019
Premier Injury Clinics of DFW dated 09/09/2019
Prime Diagnostic Imaging dated 08/05/2019
BILLING RECORDS AFFIDAVITS:
Dallas Radiology, P.A. dated 08/12/2019
MDN, PA dated 08/26/2019
MRI Centers of Texas dated 08/05/201 9
Orthopaedic & Spine Specialists of Texas, LLC dated 08/22/2019
Premier Injury Clinics of DFW dated 09/09/2019
Prime Diagnostic Imaging dated 08/05/2019
Uptown Radiology Associates dated 08/12/2019
RADIOLOGY IMAGING AFFIDAVITS:
MRI Centers of Texas dated 08/05/201 9
Prime Diagnostic Imaging dated 08/05/2019
PLAINTIFF’S NOTICE OF SERVICE OF FILING RECORD AFFIDAVITS AND CERTIFIED COPIES
— Page 1
By copy of this notice, opposing counsel are notified that these affidavits and
certified copies are being filed with the Court pursuant to TRE 902. The certified
copies, records and radiology corresponding to the enclosed affidavits will be kept
in Plaintiff's counsel’s office for use at trial. Opposing counsel have been
previously provided with a copy of the certified copies, affidavits and corresponding
records/radiology listed above.
Respectfully submitted,
EBERSTEIN & WITHERITE, LLP
By: /s/ V. Paige Eldridge
V. PAIGE ELDRIDGE
State Bar No. 24096747
paiqe.eldridqe@ewlawvers.com
AMY K. WITHERITE
State Bar No. 00788698
amv.witherite@ewlawvers.com
10440 N. Central Expressway, Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
hereby certify that a true and correct copy of the foregoing has been
|
forwarded to all counsel of record on this 20th day of July pursuant to Rule 21a of
the Texas Rules of Civil Procedure.
/s/ V. Paige Eldridge
V. Paige Eldridge
Adam B. LeCrone
The LeCrone Law Firm, P.C.
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman, TX 75090
PLAINTIFF’S NOTICE OF SERVICE 0F FILING RECORD AFFIDAVITS AND CERTIFIED COPIES
— Page 2
TEXAS DEPARTMENT OF PUBLIC SAFETY
5805 N LAMAR BLVD BOX 4087° AUSTIN, TEXAS 78773—0001
www.dps.texas.gov
DRIVER LICENSE DIVISION
5 12-424-2600
STEVEN c, McCRAw .
EN ESPANOL 512‘424'7181 COMMISSION
DIRECTOR t
STEVEN P. MACH, CHAIRMAN
SKYLOR HEARN V MANNY FLORES
FREEMAN F, MARTIN A. CYNTHIA LEON
RANDALL B. PRINCE JASON K. PULLIAM
DEPUTY DIRECTORS RANDY WATSON
CERTIFIED ABSTRACT RECORD: 08/06/2019
~ THIS TYPE OF RECORD
WILL REFLECT COMPLETION OF A DRIVING SAFETY COURSE.
~ THIS RECORD REFLECTS ENFORCEMENTACTIONS, CONVICTIONS, AND CRASH INVOLVEMENTS THATARE ALLOWED
TO BE DlSF’LA YED BYLAW.
REQUESTED BY:
GOMEZ, JAMES PAUL
Date of Birth;
Sex: MALE
No REPORT 0F APPROVED DRIVER EDUCATION COURSE. Eye Color; BROWN
DRIVER LICENSE AND COMMERCIAL LEARNERS PERMIT INFORMATION
Driver License Number: 9088 License Type: DL License Class: CM
Date Originally Issued: 08/12/1991 Date Last issued: 06/20/2019 Date of Expiration: 10/06/2021
Restrictions: With Corrective Lenses; Licensed MC Operator 21 Or Over In Sight
Endorsements: NONE
STATUS [N FORMATION Driver eligibility reflects a person’s eligibility to drive at the time this document was requested.
Administrative Status details additional notes related to the person's record that do not affect driving eligibility.
Driver Eligibility: ELIGIBLE
Administrative Status: NONE
ENFORCEMENT ACT|0N H|STORY This section displays enforcement actions that may affect a person ’s eligibility
to drive. Additional information pertaining to any event related to the enforcement
action can be found In the Event Section of this record.
THE RECORD CONTAINS NO HISTORY OF ENFORCEMENT ACTIONS
DRIVER RESPONS|B|L|TY PROGRAM (DRP) This section displays information relating the Driver Responsibility
Program A_ny suspension action resulting from a notice will be
referenced'm the Enforcement Action History Section
THE RECORD CONTAINS NO HISTORY OF DRP CASES
EVENT HISTORY This section displays information relating to convictions, crash involvement, safety courses completed,
out—ofistate surrendered license history and education program cerflflcaz‘es.
EVENTA1 COURSE DRIVING SAFETY COURSE
Page 1
IGOMEZ, JAMES PAUL - CERTIFIED ABSTRACT RECORD - 08/06/2019
Offense Date: 11/07/2017 Completion Date: 02/21/2018
County: MONTGOMERY Court Name: Justice of the
Peace Court
(offense =
Texas
Court)
Case/Cause/Docket #2 001 0029911
EVENT 2 COURSE DRIVING SAFETY COURSE I
Offense Date: 08/04/201 5 Completion Date: 11/28/201 5
City: GRAND PRAIRIE Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Dooket #: N00821 5201
EVENT 3 COURSE DRIVING SAFETY COURSE
Offense Date: 01/01/2014 Completion Date: 05/29/2014
City: WILMER Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Docket #2 0031 394901
EVENT 4 COURSE DRIVING SAFETY COURSE
Offense Date: 08/20/2009 Completion Date: 12/14/2009
City: GRAND PRAIRIE Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Docket #: K031912201
EVENT 5 COURSE DRIVING SAFETY COURSE
Offense Date: 09/12/2007 Completion Date: 11/30/2007
City: HURST Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Docket #: 040041 554
EVENT 6 CONVICTION SPEEDING EQUAL T0 OR GREATER THAN 10% ABOVE POSTED LIMIT
Offense Date: 07/23/2006 Conviction Date: 01/05/2007 County: NAVARRO
State: TX Court Name: Justice of the
Peace Court
(offense =
Texas
Court)
Case/Cause/Docket No: 3430.90
CMV: NO HAZIVIAT: NO‘ CDL: NO
EVENT 7 CONVICTION SPEEDING v
V
r
Offense Date: 07/08/2005 Conviction Date: 12/05/2005 County: WILLIAMSON
State: TX Court Name: Justice of the
Peace Court
(offense =
Texas
Court)
Case/Cause/Dooket No:CR054452
CMV: NO HAZMAT: NO CDL: NO
EVENT 8 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE
Offense Date: 12/03/1 996 Conviction Date: 06/23/1997
Page 2
IGOMEZ, JAMES PAUL - CERTIFIED ABSTRACT RECORD - 08/06/2019
City: IRVING State: TX Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Docket N02836302~2
CMV: NO HAZMAT: NO CDL: NO
Pursuant to the authority contained in the Texas Rules of Evidence 902, Section 4, and Transportation Code, Section 521, I,Manuel A. Rodriguez, do
hereby certify that am the custodian of driver records of the Driver License Division, Texas Department of Public Safety. The information contained
l
herein is true and correct as taken from our official records. This is to certify that notices of convictions for the traffic law violations and incidents of
motor vehicle accident invoivement are received and recorded, along with the official action by the Department of Public Safety, in the computer records
of JAMES PAUL GOMEZ.
In Testimony Whereof, I hereunto set my hand and affix the Sea! of the Department of Public Safety of the State of Texas on 08/06/201 9.
Manuel A. Rodriguez
Texas Department of ?ublic Safety
End 0f Record
Page 3
MEDICAL RECORDS AFFIDAVIT OF MDN, P.A.
REGARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
§
COUNTY 0F Tarrant
§
BEFORE ME, the undersigned authority, personally appeared
Edwardo Dehoyos , who, being by me duly sworn, deposed as follows:
My name is Edwardo Dehoyos . I am of sound mind, capable of making
this AffidaVit- arid personally acquainted with the facts herein stated
| am the custodian of the records of MDN. P.A.. Attached hereto are records from MDN P A
regarding Vashone Rhodes. These records are kept by MDN, P.A. in the regular course of business,
and it was in the regular course of business for an employee or representative with knowledge of the act,
event condmon oplnlon or diagnosis recorded to make the record or to transmit information thereof to
be Included tn such record; and the record was made at or near the tlme of the event recorded or
reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
original.
CUSTODIAN OF MEDICAL RECORDS
SWORN To AND SUBSCRIBED before me on the 26 day of August ,
20 19
STEPHANIE DIANA DEHovos
HE STATE OF TEXAS:
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MEDICAL RECORDS AFFIDAVIT OF MR1 CENTERS 0F TEXAS
REGARDING PATIENT VASHONE RHODES
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undersigned authority, personally
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appeared
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this Affidavit! and personally acquainted with the facts herein stated:
| am MRI Centers of Texas. Attached hereto are records from
the custodian of the records of
MRI Centers Texas regarding Vashone Rhodes. These records are kept by MRl Centers of Texas in
of
the regular course of business, and was in the regular course of business for an employee or
it
representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the
record or to transmit information thereofto be included in such record; and the record was made at or
near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the
original or exact duplicates of the original.
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EDICAL. RECQRDS AFFIDAVIT OF ORTHOPAE_D|C & SPINE SPECIAEISTS OF TEXAS, LLC
REGARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
§
COUNTY OF Dd, gs I
§
EF RE . the undersigned authority, personally appeared
aPene 01%?! ,
who, being by me duly sworn, deposed as follows:
My name is Shalene DIXON . | am of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated:
Iam the custodian of the records of Orthopaedic & Spine Specialists of Texas, LLC. Attached
hereto are records from Orthopaedic & Spine Specialists of Texas, LLC regarding Vashone Rhodes.
These records are kept by Orthopaedic & Spine Specialists of Texas, LLC in the regular course of
business, and it was in the regular course of business for an employee or representative with knowledge
of the act, event, condition, opinion, or diagnosis 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 of the event recorded
or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
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MEDICAL RECORDS AFFIDAVIT OF PREMIER INJURY CLINICS OF DFW
REGARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
§
COUNTY 0F &> §
BEFORE ME, the undersigned authority, personally appeared
x
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who eing b me dui)\sworn, deposed as follows:
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am of sound mind, capable of making
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this Affidavit. and personally acquainted with the facts herein stated:
I am the custodian of the records of Premier Injury Clinics of DFW. Attached hereto are records
from Premier Injury Clinics of DFW regarding Vashone Rhodes. These records are kept by Premier
Injury Clinics of DFW in the regular course of business, and it was in the regular course of business for
an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis 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 of the event recorded or reasonably soon thereafter. The records r
hereto are the original or exact duplicates of the original.
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CUSTODIAN OF MEDICAL RECORDS
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MEDICAL RECORDS AFFIDAVIT OF PRIMjELDIAGNOSTIC IMAGING ’
REflRDING PATIENT VASHONE RHODES
STATE 0F TEXAS §
§
COUNTY OF EZM‘ I
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the undersigned authority, personally appeared
M vfl \l i I 0L .
who, being by me duly sworn, deposed as follows:
My name is
1mg IQ! jfi: [I IQ . I am of sound mind, capable of making
this Affidavit. and personally acquainte 3 with the facts herein stated:
Iam the custodian of the records of Prime Diagnostic Imaglng. Attached hereto are records from
Prime Diagnostic Imaging regarding Vashone Rhodes. These records are kept by Prime Diagnostic
Imaging in the regular course of business, and it was in the regular course of business for an employee
or representative with knowledge of the act. event, condition, opinion, or diagnosis 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 of the event recorded or reasonably soon thereafter. The records attached hereto are the
original 0r exact duplicates of the original.
nmka/QN‘x/m
CUSTODIAN OF MEDICAL RECORDS
SWORN T0 AND SUBSCRIBED before me on the 6 day 0f Z? M £62 .
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AFFIDAVIT OF R_E_COR_DS CUSTODIAN OF DALLAS RADIOLOGY P.A.
REGARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
COUNTY 0F 24/143 g
BEFORE ME, the undersigned authority, personally appeared
who, being byme duly sworn, deposed as follows:
Am MUN}?
f
My name
this Affidavit,
is An“ m ”4°;
and personally acquainted with the facts herein stated.
. I am of sound mind, capable of making
Iam a custodian of records for Dallas Radiology, P.A.. Attached to this Affidavit are records that
provide an itemized statement of the service and the charge for the service that Dallas Radiology, P.A.
provided to Vashone Rhodes on 11/27/2018 to present. The attached records are a part of this affidavit.
The attached records are kept by Dallas Radiology. P.A. in the regular course of business, and it
was the regular course of business of Dallas Radiology. P.A. for an employee or representative of Dallas
Radiology, P.A., with knowledge of the service provided, to make the record or to transmit information to
be included in the record. The records were made in the regular course of business at or near the time
or reasonably soon after the time the service was provided. The records are the original or a duplicate of
the original.
The services provided were necessary and the amount charged for the service was reasonable
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at the time and place that the services were provided.
The total amount paid
which Dallas Radiology, P.A. has a
for the services
right to
was $
be paid
a
after
and the amount currently unpaid but
any adjustments or credits is $ a 0°
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CUSTODIAN OF BILLING RECORfi’
SWORN TO AND SUBSCRIBED before me on the IL day of mans i ,
20 '4 .
NOTARY PUBLIC IN
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AND FOR THE STATE OF TEXAS:
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NOTARY'S PRINTED AME: '
MY COMMISSION EXPIRES: ?fll’ll,
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AFFIDAVIT 0F RECORDS CUSTODIAN OF MDN, P.A.
REGARDING PATIENT VASHONE RHODES
STATE 0F TEXAS §
§
COUNTY OF Tarrant §
BEFORE ME, the undersigned authority. personally appeared Edwardo Dehoyos ,
who, being by me duly sworn, deposed as follows:
My name is Edwardo Dehoyos . I am of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated.
am a custodian of records for MDN, P.A.. Attached to this Affidavit are records that provide an
|
itemized statement of the service and the charge for the service that MDN, P.A. provided to Vashone
Rhodes on 11/27/2018 to present. The attached records are a part of this affidavit.
The attached records are kept by MDN, P.A. in the regular course of business, and was the it
regular course of business of MDN, P.A. for an employee or representative of MDN, P.A., with knowledge
of the service provided, to make the record or to transmit information to be included in the record. The
records were made in the regular course of business at or near the time or reasonably soon after the
time the service was provided. The records are the original or a duplicate of the original.
The services provided were necessary and the amount charged for the service was reasonable
at the time and placethat the services were provided.
The total amount paid for the services was $ 0-00 and the amount currently unpaid but
which MDN, P.A. has a right to be paid after any adjustm credits is $ 1690.00 .
CUSTODIAN O ILLING RECORDS
sw0RN To AND SUBSCRIBED before me on the 26 day of August ,
20 19
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AFFIDAVIT 0F RECORDS CUSTODIAN OF MRI CENTERS OF TEXAS
REGARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
COUNTY OFg kl {OS g v
BEFORE ME, the undersigned authority, personally appeared fldY \Clfl a Lecu gma
who, being by me duly sworn deposed as follows:
this Affidavit
My name is my ‘0 ma
and personally acquainted with the
Lat gma .l
facts herein stated.
am of sound mind, capable of making
am a custodian of records for MRI Centers of Texas. Attached to this Affidavit are records that
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provide an itemized statement of the service and the charge for the service that MR1 Centers of Texas
provided to Vashone Rhodes 0n 11/27/2018 to present. The attached records are a part of this affidavit.
The attached records are kept by MRI Centers of Texas in the regular course of business. and it
was the regular course of business of MRI Centers of Texas for an employee or representative of MRI
Centers of Texas, with knowledge of the service provided, to make the record or to transmit information
to be included in the record. The records were made in the regular course of business at or near the time
or reasonably soon after the time the service was provided. The records are the original or a duplicate of
the original.
The services provided were necessary and the amount charged for the service was reasonable
at the time and place that the services were provided.
The total amount paid for the services was D and the amount cur en I but
'
ad
which MRI Centers of Texas has a rightt r any adjustments or credits Is
CUSTODIAN OF BILLING RECORDS
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AFFIDAVIT OF RECORDS CUSTODIAN OF ORTHOPAEDIC & SPINE SPECIALISTS 0F TEXAS.
LLC
_R_§GARDING PATIENT VASHONE RHODES
STATE OF TEXAS §
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BEFORE ME, the undersigned authority, personally appeared Shalene Dixon
who, being byme duly sworn, deposed as follows:
My name is Shalene Dixon . | am of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated.
| am & Spine Specialists of Texas, LLC. Attached to this
a custodian of records for Orthopaedic
an itemized statement of the service and the charge for the service that
Affidavit are records that provide
Orthopaedic & Spine Specialists of Texas, LLC provided to Vashone Rhodes on 11/27/2018 to present.
The attached records are a part of this affidavit.
The attached records are kept by Orthopaedic & Spine Specialists of Texas, LLC in the regular
course of business, and it was the regular course of business of Orthopaedic & Spine Specialists of
Texas, LLC for an employee or representative of Orthopaedic & Spine Specialists of Texas, LLC, with
knowledge of the service provided, to make the record or to transmit information to be included in the
record. The records were made in the regular course of business at or near the time or reasonably soon
after the time the service was provided. The records are the original or a duplicate of the original.
The services provided were necessary and the amount charged for the service was reasonable
at the time and place that the services were provided.
The amount paid for the services was $
total
which Ortho ae ic & Spine Specialists
creditsis$ 'ZZ 0.90 .
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AFFIDAVIT OF RECORDS CUSTODIAN OF PREMIER INJURY CLINICS OF DFW
REGARDING PATIENT VASHONE RHODES
STATE 0F TEXAS §
coUNTY 0F "iC—«mx
who, being by
this Affidavit,
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and personally acquainted with the
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Preview
FILED 7/20/2020 10:47 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Miranda Lynch DEPUTY CAUSE NO. DC-1 9-1 0926 VASHONE RHODES; § IN THE DISTRICT COURT OF Plaintiff, g VS. g DALLAS COUNTY, TEXAS JAMES GOMEZ; g Defendant. g 160th JUDICIAL DISTRICT PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES Plaintiff Vashone Rhodes files with the Court the attached record affidavits and certified copies: STATE RECORDS: Defendant’s Certified Driving Record MEDICAL RECORDS AFFIDAVITS: MDN, PA dated 08/26/2019 MRI Centers of Texas dated 08/05/201 9 Orthopaedic & Spine Specialists of Texas, LLC dated 08/22/2019 Premier Injury Clinics of DFW dated 09/09/2019 Prime Diagnostic Imaging dated 08/05/2019 BILLING RECORDS AFFIDAVITS: Dallas Radiology, P.A. dated 08/12/2019 MDN, PA dated 08/26/2019 MRI Centers of Texas dated 08/05/201 9 Orthopaedic & Spine Specialists of Texas, LLC dated 08/22/2019 Premier Injury Clinics of DFW dated 09/09/2019 Prime Diagnostic Imaging dated 08/05/2019 Uptown Radiology Associates dated 08/12/2019 RADIOLOGY IMAGING AFFIDAVITS: MRI Centers of Texas dated 08/05/201 9 Prime Diagnostic Imaging dated 08/05/2019 PLAINTIFF’S NOTICE OF SERVICE OF FILING RECORD AFFIDAVITS AND CERTIFIED COPIES — Page 1 By copy of this notice, opposing counsel are notified that these affidavits and certified copies are being filed with the Court pursuant to TRE 902. The certified copies, records and radiology corresponding to the enclosed affidavits will be kept in Plaintiff's counsel’s office for use at trial. Opposing counsel have been previously provided with a copy of the certified copies, affidavits and corresponding records/radiology listed above. Respectfully submitted, EBERSTEIN & WITHERITE, LLP By: /s/ V. Paige Eldridge V. PAIGE ELDRIDGE State Bar No. 24096747 paiqe.eldridqe@ewlawvers.com AMY K. WITHERITE State Bar No. 00788698 amv.witherite@ewlawvers.com 10440 N. Central Expressway, Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE hereby certify that a true and correct copy of the foregoing has been | forwarded to all counsel of record on this 20th day of July pursuant to Rule 21a of the Texas Rules of Civil Procedure. /s/ V. Paige Eldridge V. Paige Eldridge Adam B. LeCrone The LeCrone Law Firm, P.C. Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman, TX 75090 PLAINTIFF’S NOTICE OF SERVICE 0F FILING RECORD AFFIDAVITS AND CERTIFIED COPIES — Page 2 TEXAS DEPARTMENT OF PUBLIC SAFETY 5805 N LAMAR BLVD BOX 4087° AUSTIN, TEXAS 78773—0001 www.dps.texas.gov DRIVER LICENSE DIVISION 5 12-424-2600 STEVEN c, McCRAw . EN ESPANOL 512‘424'7181 COMMISSION DIRECTOR t STEVEN P. MACH, CHAIRMAN SKYLOR HEARN V MANNY FLORES FREEMAN F, MARTIN A. CYNTHIA LEON RANDALL B. PRINCE JASON K. PULLIAM DEPUTY DIRECTORS RANDY WATSON CERTIFIED ABSTRACT RECORD: 08/06/2019 ~ THIS TYPE OF RECORD WILL REFLECT COMPLETION OF A DRIVING SAFETY COURSE. ~ THIS RECORD REFLECTS ENFORCEMENTACTIONS, CONVICTIONS, AND CRASH INVOLVEMENTS THATARE ALLOWED TO BE DlSF’LA YED BYLAW. REQUESTED BY: GOMEZ, JAMES PAUL Date of Birth; Sex: MALE No REPORT 0F APPROVED DRIVER EDUCATION COURSE. Eye Color; BROWN DRIVER LICENSE AND COMMERCIAL LEARNERS PERMIT INFORMATION Driver License Number: 9088 License Type: DL License Class: CM Date Originally Issued: 08/12/1991 Date Last issued: 06/20/2019 Date of Expiration: 10/06/2021 Restrictions: With Corrective Lenses; Licensed MC Operator 21 Or Over In Sight Endorsements: NONE STATUS [N FORMATION Driver eligibility reflects a person’s eligibility to drive at the time this document was requested. Administrative Status details additional notes related to the person's record that do not affect driving eligibility. Driver Eligibility: ELIGIBLE Administrative Status: NONE ENFORCEMENT ACT|0N H|STORY This section displays enforcement actions that may affect a person ’s eligibility to drive. Additional information pertaining to any event related to the enforcement action can be found In the Event Section of this record. THE RECORD CONTAINS NO HISTORY OF ENFORCEMENT ACTIONS DRIVER RESPONS|B|L|TY PROGRAM (DRP) This section displays information relating the Driver Responsibility Program A_ny suspension action resulting from a notice will be referenced'm the Enforcement Action History Section THE RECORD CONTAINS NO HISTORY OF DRP CASES EVENT HISTORY This section displays information relating to convictions, crash involvement, safety courses completed, out—ofistate surrendered license history and education program cerflflcaz‘es. EVENTA1 COURSE DRIVING SAFETY COURSE Page 1 IGOMEZ, JAMES PAUL - CERTIFIED ABSTRACT RECORD - 08/06/2019 Offense Date: 11/07/2017 Completion Date: 02/21/2018 County: MONTGOMERY Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket #2 001 0029911 EVENT 2 COURSE DRIVING SAFETY COURSE I Offense Date: 08/04/201 5 Completion Date: 11/28/201 5 City: GRAND PRAIRIE Court Name: Municipal Court (offense = Texas Court) Case/Cause/Dooket #: N00821 5201 EVENT 3 COURSE DRIVING SAFETY COURSE Offense Date: 01/01/2014 Completion Date: 05/29/2014 City: WILMER Court Name: Municipal Court (offense = Texas Court) Case/Cause/Docket #2 0031 394901 EVENT 4 COURSE DRIVING SAFETY COURSE Offense Date: 08/20/2009 Completion Date: 12/14/2009 City: GRAND PRAIRIE Court Name: Municipal Court (offense = Texas Court) Case/Cause/Docket #: K031912201 EVENT 5 COURSE DRIVING SAFETY COURSE Offense Date: 09/12/2007 Completion Date: 11/30/2007 City: HURST Court Name: Municipal Court (offense = Texas Court) Case/Cause/Docket #: 040041 554 EVENT 6 CONVICTION SPEEDING EQUAL T0 OR GREATER THAN 10% ABOVE POSTED LIMIT Offense Date: 07/23/2006 Conviction Date: 01/05/2007 County: NAVARRO State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No: 3430.90 CMV: NO HAZIVIAT: NO‘ CDL: NO EVENT 7 CONVICTION SPEEDING v V r Offense Date: 07/08/2005 Conviction Date: 12/05/2005 County: WILLIAMSON State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Dooket No:CR054452 CMV: NO HAZMAT: NO CDL: NO EVENT 8 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE Offense Date: 12/03/1 996 Conviction Date: 06/23/1997 Page 2 IGOMEZ, JAMES PAUL - CERTIFIED ABSTRACT RECORD - 08/06/2019 City: IRVING State: TX Court Name: Municipal Court (offense = Texas Court) Case/Cause/Docket N02836302~2 CMV: NO HAZMAT: NO CDL: NO Pursuant to the authority contained in the Texas Rules of Evidence 902, Section 4, and Transportation Code, Section 521, I,Manuel A. Rodriguez, do hereby certify that am the custodian of driver records of the Driver License Division, Texas Department of Public Safety. The information contained l herein is true and correct as taken from our official records. This is to certify that notices of convictions for the traffic law violations and incidents of motor vehicle accident invoivement are received and recorded, along with the official action by the Department of Public Safety, in the computer records of JAMES PAUL GOMEZ. In Testimony Whereof, I hereunto set my hand and affix the Sea! of the Department of Public Safety of the State of Texas on 08/06/201 9. Manuel A. Rodriguez Texas Department of ?ublic Safety End 0f Record Page 3 MEDICAL RECORDS AFFIDAVIT OF MDN, P.A. REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § § COUNTY 0F Tarrant § BEFORE ME, the undersigned authority, personally appeared Edwardo Dehoyos , who, being by me duly sworn, deposed as follows: My name is Edwardo Dehoyos . I am of sound mind, capable of making this AffidaVit- arid personally acquainted with the facts herein stated | am the custodian of the records of MDN. P.A.. Attached hereto are records from MDN P A regarding Vashone Rhodes. These records are kept by MDN, P.A. in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event condmon oplnlon or diagnosis recorded to make the record or to transmit information thereof to be Included tn such record; and the record was made at or near the tlme of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. CUSTODIAN OF MEDICAL RECORDS SWORN To AND SUBSCRIBED before me on the 26 day of August , 20 19 STEPHANIE DIANA DEHovos HE STATE OF TEXAS: 10,1” 3;"!23: {:47 6-5 Hotavy Public State o! Texas “mm ’Sli 5;.” “3-: Cc mm Expnes 01 -Ob 2020 huéj ,. Notary ID 130487105 Stephanie Dehoyos NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: M20— MEDICAL RECORDS AFFIDAVIT OF MR1 CENTERS 0F TEXAS REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § COUNTY OF w‘ [Clg g Rd V 85%? w? \ I \v g Me , undersigned authority, personally who, being by me duly sworn, deposed as follows: appeared My name is fldv \ona \eflnma . | am of sound mind, capable of making this Affidavit! and personally acquainted with the facts herein stated: | am MRI Centers of Texas. Attached hereto are records from the custodian of the records of MRI Centers Texas regarding Vashone Rhodes. These records are kept by MRl Centers of Texas in of the regular course of business, and was in the regular course of business for an employee or it representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereofto be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. cus‘fobIA‘N'OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED before me on the gmday of E h Ag} JS+ . 20E. {$923024 VNINA A. ,Dms $53M NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS: QgNotary Public. State of Texas 9): »5‘ -- +T~ t Comm. Expires 06-14-2020 H‘a‘ ’llfilm“ Nozary ID 130700473 N\ fl a fl \d‘ - i 3 NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: l £’l ‘I ’10 EDICAL. RECQRDS AFFIDAVIT OF ORTHOPAE_D|C & SPINE SPECIAEISTS OF TEXAS, LLC REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § § COUNTY OF Dd, gs I § EF RE . the undersigned authority, personally appeared aPene 01%?! , who, being by me duly sworn, deposed as follows: My name is Shalene DIXON . | am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: Iam the custodian of the records of Orthopaedic & Spine Specialists of Texas, LLC. Attached hereto are records from Orthopaedic & Spine Specialists of Texas, LLC regarding Vashone Rhodes. These records are kept by Orthopaedic & Spine Specialists of Texas, LLC in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis 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 of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the mm mm C/(JSTODIAN 0F MEDICAL RECORDS SWORN To AND SUBSCRIBED before me on the £9; day of ,Au‘é/Mfit' . 20/3 . NOTARY Puslfl IN AND’FOR THE STATE 0F TEXAS: . Ast‘ mfllflm m.mamu w mum 03/12/2023 24m: MY COMMISSION umw @cmznmod NOTARY'S PRINTED NAME: EXPIRES: m MEDICAL RECORDS AFFIDAVIT OF PREMIER INJURY CLINICS OF DFW REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § § COUNTY 0F &> § BEFORE ME, the undersigned authority, personally appeared x , who eing b me dui)\sworn, deposed as follows: Li My name is {Q Ml 8Y0“ Em g uiova am of sound mind, capable of making . I this Affidavit. and personally acquainted with the facts herein stated: I am the custodian of the records of Premier Injury Clinics of DFW. Attached hereto are records from Premier Injury Clinics of DFW regarding Vashone Rhodes. These records are kept by Premier Injury Clinics of DFW in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis 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 of the event recorded or reasonably soon thereafter. The records r hereto are the original or exact duplicates of the original. W CUSTODIAN OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED before me on the E's day of Wm} 35 . “gégg’fi $« -----.0gymwotarv :0; 5:5. \\ I "1m H“ I. N oEMi' OLIVAs Pub 11c State of T9” .555 Comm..Exp“95 ’W'5;'<€‘§‘ - ' 05'27'2022 .Notary ID 129830646 s m NOTARY PUBLIC MY COMMISSION I \ m\\gc“<‘ 'NOTARY'S PRINTED NAME: EXPIRES:m a R THE STATE OF TEXAS: , m “5'06?“ MEDICAL RECORDS AFFIDAVIT OF PRIMjELDIAGNOSTIC IMAGING ’ REflRDING PATIENT VASHONE RHODES STATE 0F TEXAS § § COUNTY OF EZM‘ I as _ § gEFiRE ktE, the undersigned authority, personally appeared M vfl \l i I 0L . who, being by me duly sworn, deposed as follows: My name is 1mg IQ! jfi: [I IQ . I am of sound mind, capable of making this Affidavit. and personally acquainte 3 with the facts herein stated: Iam the custodian of the records of Prime Diagnostic Imaglng. Attached hereto are records from Prime Diagnostic Imaging regarding Vashone Rhodes. These records are kept by Prime Diagnostic Imaging in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act. event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original 0r exact duplicates of the original. nmka/QN‘x/m CUSTODIAN OF MEDICAL RECORDS SWORN T0 AND SUBSCRIBED before me on the 6 day 0f Z? M £62 . 9 NOTARY PUB I .- -j THE STATE 0F TEXAS. J NOTARY'S E—R‘la | ED NAME: 3 / MY COMMISSION EXPIRES: g _ .1 AAr ’1~g${?gg¢, REBECCA K DYEH ??i' ‘-.%"-':- Notary Public State of Texas ‘1“.“1’ '54} §.Comm Expirosm- 18- 2020 :‘\\-. ?,mm‘ Notary Io 130499833 ~— T w..— I AFFIDAVIT OF R_E_COR_DS CUSTODIAN OF DALLAS RADIOLOGY P.A. REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § COUNTY 0F 24/143 g BEFORE ME, the undersigned authority, personally appeared who, being byme duly sworn, deposed as follows: Am MUN}? f My name this Affidavit, is An“ m ”4°; and personally acquainted with the facts herein stated. . I am of sound mind, capable of making Iam a custodian of records for Dallas Radiology, P.A.. Attached to this Affidavit are records that provide an itemized statement of the service and the charge for the service that Dallas Radiology, P.A. provided to Vashone Rhodes on 11/27/2018 to present. The attached records are a part of this affidavit. The attached records are kept by Dallas Radiology. P.A. in the regular course of business, and it was the regular course of business of Dallas Radiology. P.A. for an employee or representative of Dallas Radiology, P.A., with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the service was reasonable QM at the time and place that the services were provided. The total amount paid which Dallas Radiology, P.A. has a for the services right to was $ be paid a after and the amount currently unpaid but any adjustments or credits is $ a 0° 1g . CUSTODIAN OF BILLING RECORfi’ SWORN TO AND SUBSCRIBED before me on the IL day of mans i , 20 '4 . NOTARY PUBLIC IN A MM? AND FOR THE STATE OF TEXAS: fidnufi Vasavn; NOTARY'S PRINTED AME: ' MY COMMISSION EXPIRES: ?fll’ll, SIDNEY VASQUEZ Notary 'D 3129708752 My Commision Expires February 11, 2022 AFFIDAVIT 0F RECORDS CUSTODIAN OF MDN, P.A. REGARDING PATIENT VASHONE RHODES STATE 0F TEXAS § § COUNTY OF Tarrant § BEFORE ME, the undersigned authority. personally appeared Edwardo Dehoyos , who, being by me duly sworn, deposed as follows: My name is Edwardo Dehoyos . I am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated. am a custodian of records for MDN, P.A.. Attached to this Affidavit are records that provide an | itemized statement of the service and the charge for the service that MDN, P.A. provided to Vashone Rhodes on 11/27/2018 to present. The attached records are a part of this affidavit. The attached records are kept by MDN, P.A. in the regular course of business, and was the it regular course of business of MDN, P.A. for an employee or representative of MDN, P.A., with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the service was reasonable at the time and placethat the services were provided. The total amount paid for the services was $ 0-00 and the amount currently unpaid but which MDN, P.A. has a right to be paid after any adjustm credits is $ 1690.00 . CUSTODIAN O ILLING RECORDS sw0RN To AND SUBSCRIBED before me on the 26 day of August , 20 19 No A PUBLIC IN Dvw AND FgR THE STATE 0F TEXAS: elfgofi. STEPHANIE DIANA DEHOYOS Noiory Puohc, Slave o! . 7kg?ins Iexos C‘gm't“ Exnnes 01 06.2070 Stephanie Dehoyos Brég§ “ , NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: “06/2020 AFFIDAVIT 0F RECORDS CUSTODIAN OF MRI CENTERS OF TEXAS REGARDING PATIENT VASHONE RHODES STATE OF TEXAS § COUNTY OFg kl {OS g v BEFORE ME, the undersigned authority, personally appeared fldY \Clfl a Lecu gma who, being by me duly sworn deposed as follows: this Affidavit My name is my ‘0 ma and personally acquainted with the Lat gma .l facts herein stated. am of sound mind, capable of making am a custodian of records for MRI Centers of Texas. Attached to this Affidavit are records that I provide an itemized statement of the service and the charge for the service that MR1 Centers of Texas provided to Vashone Rhodes 0n 11/27/2018 to present. The attached records are a part of this affidavit. The attached records are kept by MRI Centers of Texas in the regular course of business. and it was the regular course of business of MRI Centers of Texas for an employee or representative of MRI Centers of Texas, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the service was reasonable at the time and place that the services were provided. The total amount paid for the services was D and the amount cur en I but ' ad which MRI Centers of Texas has a rightt r any adjustments or credits Is CUSTODIAN OF BILLING RECORDS JOMQ _hday of ml 1‘01/19' SWORN TO AND SUBSCRIBED before me on the5 20 ‘Q. ASM . o\\\IIIII NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS: ”$2 NINA A. IDRIS "I [Ill t3. .30”! ‘SI \ \\ ?dflk * mnuw‘ n: _Notary .3: Comm. Public, State of Texas Expires 06- 14- 2020 Nma Qv \dviS Notary ID 130700473 NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: ('4' Q AFFIDAVIT OF RECORDS CUSTODIAN OF ORTHOPAEDIC & SPINE SPECIALISTS 0F TEXAS. LLC _R_§GARDING PATIENT VASHONE RHODES STATE OF TEXAS § COUNTY 0F {2mm g BEFORE ME, the undersigned authority, personally appeared Shalene Dixon who, being byme duly sworn, deposed as follows: My name is Shalene Dixon . | am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated. | am & Spine Specialists of Texas, LLC. Attached to this a custodian of records for Orthopaedic an itemized statement of the service and the charge for the service that Affidavit are records that provide Orthopaedic & Spine Specialists of Texas, LLC provided to Vashone Rhodes on 11/27/2018 to present. The attached records are a part of this affidavit. The attached records are kept by Orthopaedic & Spine Specialists of Texas, LLC in the regular course of business, and it was the regular course of business of Orthopaedic & Spine Specialists of Texas, LLC for an employee or representative of Orthopaedic & Spine Specialists of Texas, LLC, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the service was reasonable at the time and place that the services were provided. The amount paid for the services was $ total which Ortho ae ic & Spine Specialists creditsis$ 'ZZ 0.90 . m Texas, LLC has a QUSTODIAN OF SWORN TO AND SUBSCRIBED before me on the ZZ a fl BILLIN and the amount currently unpaid but right to be paid after any adjustments or flu» RECORDS p4 day of I , 201 i . NOTARY PUByC IN AND FOR THE STATEbF TEXAS: a “V'SWW ' ° “WW“T“ 4442/“ 1. NOTARY'S PRINTED NAME: WW IEE/MMJM ' O.HMOE?‘ MY COMMISSION EXPIRES: 12/ av AFFIDAVIT OF RECORDS CUSTODIAN OF PREMIER INJURY CLINICS OF DFW REGARDING PATIENT VASHONE RHODES STATE 0F TEXAS § coUNTY 0F "iC—«mx who, being by this Affidavit, My name is and personally acquainted with the § § BEFORE ME, the undersigned authority, personally appeared me mg sworn. deposed as follows: thYM‘ SQMOV a \ . l am