Preview
FILED
8/6/2020 1:09 PM
FELICIA PITRE
DISTRICT CLERK
Contains Sensitive Data DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
CAUSE NO. DC-20-04620
ABIGAIL M. ARROYO and EMMA § IN THE DISTRICT COURT
R. ALARCON §
§
V. § 160TH JUDICIAL DISTRICT
§
VICTORIA C. HUFFSTUTLER §
§ DALLAS COUNTY, TEXAS
§
DEFENDANT’S COUNTER-AFFIDAVIT PURSUANT TO SECTION 18.001
OF THE TEXAS CIVIL PRACTICES & REMEDIES CODE
RE: MEDICAL & BILLING AFFIDAVITS
STATE OF TEXAS §
§ KNOWN ALL MEN BY THESE PRESENTS:
COUNTY OF DALLAS §
BEFORE ME, the undersigned authority, a notary public in and for the State of Texas,
0n this day personally appeared Lennard A. Nadalo, M.D., F.A.C.R. who being by me first
duly sworn upon his oath, deposed as stated:
“My name Lennard A. Nadalo, M.D., F.A.C.R. I am a licensed Medical Doctor in
is
Texas and an ABR Board Certified Radiologist. I also hold special certification in
Illinois. I am
Neuroradiology granted me by the American Board 0f Radiology. I have a BS Summa cum laude
from North Park University, Chicago, Illinois and a M.D. with Honors in Pathology and Clinical
Diagnosis from Northwestern University, Chicago, Illinois. I currently practice Diagnostic
Radiology and Neuroradiology in Methodist Dallas Medical Center, Methodist Charlton Medical
Center, Methodist McKinney Hospital, Crescent Medical Center Lancaster, First Baptist Medical
Center and Very Special Images, PLLC. I am currently on the Methodist Dallas Medical Center
and Methodist Charlton Medical Center Tumor Board. I also have a fellowship in the American
College of Radiology, F.A.C.R. (See Curriculum Vitae, attached hereto as Exhibit 'A,’
incorporated herein for all purposes.) I am over 18 years of age, 0f sound mind, and make this
affidavit upon my best information and belief. I state that I am qualified by knowledge, skill,
experience, training, education and other expertise to make the statements contained in this
affidavit and I am fillly competent to testify t0 the matters stated herein. My Texas license is
E5417. I have treated numerous patients in the field of diagnostic radiology. I practice
Diagnostic Radiology and Neuroradiology in multiple hospitals including a hospital serving a
trauma center. I have performed numerous record reviews and served as an expert Witness for
both plaintiffs and defendants in Dallas County, Collin County, Tarrant County and throughout
the State 0f Texas. I am familiar With reasonable and customary charges for evaluation and
treatment thereof in Dallas County and throughout the State 0f Texas.”
COUNTER-AFFIDAVIT OF Lennard A. Nadalo, MD, FACR Page 1
10000.0808/emonsivais
“This counter-affidavit is made pursuant to §18.001 of the TEXAS CIVIL PRACTICES &
REMEDIES CODE and is made in response t0 the following affidavits and/or records pertaining t0
Plaintiff Emma Alarcon which are attached hereto as Exhibit ‘B’:
1. Lone Star Radiology; and
2. White Rock Open Air MRI.
“Such affidavits state as a purported fact that the services outlined 0n attachments thereto
were necessary and that the charges for said services were reasonable; however, I have reviewed
the medical and billing records attached t0 the above-referenced affidavits and it is my opinion,
based 0n my training, experience, and expertise, that the health care treatment and numerous
procedures and charges, as indicated in my report dated August 4, 2020, are neither reasonable,
necessary nor justified by the condition as described by said medical reports. Please see the true
and correct copy of the report which is attached to this counter—affidavit and incorporated herein
by reference as Exhibit ‘C’.”
Further Affiant sayeth not.
%{W/¢ MM éfi/Wr
Lennard A. Nadalo, M.D., F.A.C.R.
STATE 0F TEXAS §
§
COUNTY 0F DALLAS §
SWORN TO AND SUBSCRIBED before me by Lennard A. Nadalo, M.D., F.A.C.R. on
this é day of Augue'f ,
2020, to certify which witness my hand and
official seal.
v" '04 CHROSTOPHER O FECHT
/ /\ :
F Notary ID 8131647770
l
H My Commission Expires
mow Juwmozz NOTARY PU IC-STATE WTEXAS
COUNTER-AFFIDAVIT OF Lennard A. Nadalo, MD, FACR Page 2
10000.0808/em0nsivais
EXHIBIT “A”
PERSONAL:
NAME: Lennard Albert Nadalo, MD, FACR
HOME ADDRESS: 6443 Riverview Lane
Dallas, Texas 75248
HOME TELEPHONE: 469-248-2507
CELL PHONE: 972-998-6825
E-MAIL: lennadalo@lennadalo.com
HOME FAX: 214-723-5957
HOME OFFICE: 6443 Riverview Lane
Dallas, Texas 75248
VERY SPECIAL IMAGES: 6443 Riverview Lane
Dallas, Texas 75248
GROUP PRACTICE: Radiological Consultants of North Texas
Administrative Office
816 W. Cannon St.
Fort Worth, Texas 76104
OFFICE PHONE: 817-321-0499
OFFICE FAX: 866-711-8151
EDUCATION:
COLLEGE: North Park University
5125 N. Spaulding Ave.
Chicago, Illinois 60625
Sept., 1965 - June, 1969
Summa cum laude, BA, Natural Sciences
MEDICAL SCHOOL: Northwestern University
The Feinberg School of Medicine
Morton Building 1-606
303 East Chicago Avenue
Chicago, Illinois 60611-3008
September, 1969 - June, 1973
MD, with Honors in Pathology and Clinical
Diagnosis Awarded on June 16, 1973
Revised July 13, 2020 Lennard A. Nadalo MD FACR
POST GRADUATE TRAINING AND EXPERIENCE:
INTERNSHIP: Madigan Army Medical Center
Fort Lewis
Tacoma, WA 98431 USA
253- 968-1110
July 1, 1973 - June 30, 1974
RESIDENCY: Diagnostic Radiology
San Antonio Military Medical Center
(Brooke Army Medical Center)
3851 Roger Brooke Drive
Fort Sam Houston, Texas 78234
(210) 916-4141/3400
July 1, 1974 - June 30, 1977
Armed Forces Institute of Pathology
Washington, D.C., 20012
May 10 - July 2, 1976
STAFF POSITION: Diagnostic Radiology
Tripler Army Medical Center
Jarrett White Road
(808) 433-6661
Honolulu, HI 96859-5000
July 1, 1977 – July 1, 1979.
General diagnostic radiology, angiography, pediatric
radiology, ultrasound
FELLOWSHIP: Neuroradiology and Interventional
Radiographic Procedures
Walter Reed National Military Medical Center
(Walter Reed Army Medical Center)
Washington, D.C., 20012
July 1, 1979 - June 30, 1980
INSTRUCTOR: Department of Radiology
Uniformed Services University of the
Health Sciences School of Medicine
Bethesda, Maryland
1980 - 1981
STAFF POSITION: Chief, Section of Neuroradiology and Special
Radiographic Procedures
Walter Reed Army Medical Center Washington, D.C.,
20012
July 1, 1980 - July 1, 1982
2
Revised July 13, 2020 Lennard A. Nadalo MD FACR
Neuroradiology, myelography, interventional radiology,
head of section, director of Neuroradiology and
Angiography Fellowship.
ASSISTANT PROFESSOR: Department of Radiology
Uniformed Services University of the
Health Sciences School of Medicine
Bethesda, Maryland
1981 - 1982
LECTURER: The Army Forces Institute of Pathology.
Washington, D.C.
1980 – 1982.
MILITARY SERVICE: United State Army, 1972 – 1982.
Honorable Discharge with the rank of Lt. Col. US Army
Medical Corp.
Special Training in the management of Nuclear
Radiological Disasters.
Radiological Emergency Management Team. (REM
Team)
INSTRUCTOR: Physician Associate Program
Department of Family and Preventative Medicine
The University of Oklahoma
Health Science Center
College of Medicine
900 Northeast 10th Street
Post Office Box 26901
Oklahoma City, Oklahoma 73190
(405) 271-2058
2002 – 2003.
LECTURER: University of Texas Arlington
Graduate Program, Dept. of Advanced Practice
Nursing
UT Arlington College of Nursing
2010 – 2015.
CLINICAL PROFESSOR: Department of Radiology
University of Texas Health Science
Center at Dallas
Southwestern Medical School
5323 Harry Hines Blvd.
3
Revised July 13, 2020 Lennard A. Nadalo MD FACR
Dallas, Texas 75390
1982 – 2014.
LECTURER: Family Practice Residency Program
Methodist Charlton Medical Center
Internal Medicine Residency Program
Methodist Dallas Medical Center
Current
CURRENT PROFESSIONAL ACTIVITIES:
CURRENT POSITION: Active Staff Member
Neuroradiology, & Diagnostic Radiology
Methodist Hospitals of Dallas
1441 North Beckley
PO Box 655999
Dallas, TX 75265-5999
Department of Radiology
Telephone: 214/947-2600
FAX: 214-947-2652
1982 – Present.
Radiological Consultants of North Texas
Administrative Office
816 W. Cannon St.
Fort Worth, Texas 76104
OFFICE PHONE: 817-321-0499
April 1, 2016 to present.
Very Special Images, P.L.L.C.
6443 Riverview Lane
Dallas, Texas 75248
FAX: 214-723-5957
EIN: 26-4680563
HOSPITAL APPOINTMENTS:
Methodist Dallas Medical Center, 1441 N. Beckley Ave. Dallas, Texas 75203.
214-8181. Teaching and Referral Hospital.
Methodist Charlton Medical Center, 3500 Wheatland Rd. Dallas, Texas 75237.
214-947-7777. Teaching and Full-Service Acute Care Hospital.
Methodist Mansfield Medical Center, 2700 E. Broad Street, Mansfield, TX 76063.
(682)242-2000. Full-Service Acute Care Hospital.
Methodist McKinney Hospital, 8000 W. Eldorado Parkway, McKinney, Texas
75070. Specialty Hospital.
4
Revised July 13, 2020 Lennard A. Nadalo MD FACR
CURRENT PROFESSIONAL ACTIVITY
My professional activities are centered
in the areas of DIAGNOSTIC RADIOLOGY, NEURORADIOLOGY,
ULTRASOUND, CROSS SECTIONAL BODY IMAGING and ORTHOPEDIC IMAGING. Ienjoy teaching with
an emphasis upon neuroradiology, US, CT, and MRI. | provide interpretation of diagnostic
radiographic images including x—rays, MRI, CT, US and NM. read
| cerebral sonography, duplex
sonography, and diagnostic sonography. lfully participate in the interpretation of US, MRI and CT of
a wide variety of oncologic, traumatic, infectious and orthopedic conditions. support various
| clinical
practices including neonatal ICU, ER, neuro ICU, cancer treatment, organ transplantation and trauma.
OFFICES and COMMITTEES
Cancer Committee, Methodist Dallas Medical Center, (2011— 2016)
Presenter: Methodist Dallas Medical Center, Tumor Board,
Presenter: Methodist Charlton Medical Center Tumor Board (Current)
Co-Medical Director, Envision Imaging of Allen (2004 — 2011)
Endovascular Committee, Clinical Outcomes Management (2004 — 2006)
Institutional Review Board, Methodist Medical Center. (1982-2003)
President of the Medical Staff, Methodist Medical Center. (1997-1998).
Board of Trustees, Methodist Medical Center. (1996—1999),
Chairman, Department of Radiology, Methodist Hospitals of Dallas (1998-2000)
President, Radiological Consultants Association (1998-2000)
SPECIAL INTERESTS
WebMD Author: Cervical spine trauma, Acute Stroke
Peer reviewer Journal of Computerized Axial Tomography (JCAT) (Current)
Author: eMedicine.com, Medscape.com. WebMD.com.
CERTIFICATION:
MEDICAL BOARDS: American Board of Radiology
(Diagnostic) December 7, 1977
Neuroradiology, CAQ, ABR (Current)
FLEX, December, 1975 (33235)
LICENSURE: State of Texas (E 5417) (February 28, 2021).
DEA Registration (AN8888058) (Current)
INSURANCE: Medicare Provider (M367)
Group Medicaid Provider 2000M3670
NPI #1699758276.
TMLT 1-400900
ProCPR Adult,
, Child and Infant: 158039726386604
MEDICAL ASSOCIATION MEMBERSHIP:
American College of Radiology / American Roentgen Ray Society
American Society of Neuroradiology, Senior Member
Revised July 13, 2020 Lennard A. Nadalo MD FACR
American Society of Functional Neuroradiology
American Society of Pediatric Neuroradiology
American Society of Spinal Radiology
Radiological Society of North America
Texas Radiological Society
AWARDS AND SPECIAL HONORS:
Fellowship in the American College of Radiology, FACR, May 15, 2011.
Third Annual General Graves B. Erskin Award:
"Outstanding Physician in Fellowship Training (Angiography and Neuroradiology)"
Walter Reed Army Medical Center 1979-1980.
President Medical Staff
Methodist Medical Center, 1998-1999.
Chairman
Department of Radiology
Methodist Hospitals of Dallas, 1998-2000
President
Radiological Consultants Association, 1998-2000
RECENT POST-GRADUATE EDUCATION:
American College of Radiology, Fellow
70 CME Hours January 1, 2019 – July 13, 2020.
American Board of Radiology, MOC, CAQ, Neuroradiology is current.
ASNR CME including SAMs are current.
“Case in Point,” ACR, January 1, 2019 – July 13, 2020 36 hours, CME Category 1.
Adult / Child / Infant CPR and AED Certification for Health Care
Providers (BLS) following the National Cognitive Evaluation in accordance with the ProTrainings
curriculum and the American Heart Association® guidelines. Current.
Manuscript Reviews, JCAT, (102).
PUBLICATIONS AND INVITED PRESENTATIONS:
I have served as a Clinical Professor of Radiology at the University of Texas Health Science Center at
Dallas. I have presented multiple one-hour conferences concerning Special Imaging including Spiral CT,
MRI, Sonography, and Nuclear Medicine correlation, Neuroradiology and Interventional Radiology to
the Residents in the Department of Radiology.
Current and Recent Projects:
Introduction to Pulmonary Radiology, Lectures to Internal Medicine Department, 2017-2020.
Nadalo LA, Hunter LK. Brain Abscess Imaging. Medscape Drugs & Diseases. Updated August 13,
2017. Available at: http://emedicine.medscape.com/article/336829.
Nadalo LA. Carotid Artery Stenosis Imaging. Medscape Drugs & Diseases. Available at:
http://emedicine.medscape.com/article/417524.
6
Revised July 13, 2020 Lennard A. Nadalo MD FACR
Nadalo LA, Dickerman RM, Slonim SM. Imaging in Kidney Transplantation Complications.
Medscape Drugs & Diseases. Updated 2019. Available at:
http://emedicine.medscape.com/artic|e/378801.
Nadalo LA. Lumbar Spine Trauma Imaging. Medscape Drugs & Diseases. Available at:
http://emedicine.medscape.com/articIe/398102.
Nadalo LA, Jones K. Rib Fracture Imaging. Medscape Drugs & Diseases. Available at:
http://emedicine.medscape.com/articIe/395172.
Nadalo LA. Spinal Stenosis Imaging. Medscape Drugs & Diseases. Available at:
http://emedicine.medscape.com/artic|e/344171.
Nadalo LA. Thoracic Spinal Trauma Imaging. Medscape Drugs & Diseases. Updated January 23,
2019. Available at: http://emedicine.medscape.com/artic|e/397896.
Introduction to Neuroradiology, Lecture to Internal Medicine Residents, 4/20/2017.
The Imaging of Stroke, Prevention, Early Detection and Follow-Up, Pathways of Stroke, updated,
Lecture to Internal Medicine Residents 2017.
Acute Stroke, Web MD
Cervical Spine Trauma, Web MD
Gastrointestinal Fluoroscopic Studies, 4t“ Annual Symposium for Health
Professionals. Methodist Dallas Medical Center Department of Radiology. 11/7/2015. Imaging of
Spinal Stenosis, Medscape, 4/20/2017.
Spinal Stenosis Imaging emedicine.medscape.com/artic|e/344171-overview -
Author: Lennard A Nadalo, MD; Chief Editor: James G Smirniotopoulos, MD more... Updated:
2017.
EXHIBIT “B”
f*
1 ,
)
) Cause No.:
))
2 Plaintiff,
plaintiff, ))
)
) IN THE DISTRICT COURT
3 vs.
vs. ))
)
) DALLAS COUNTY,
COUNTY, TEXAS
4 ))
))
5 Defendant,
Defendant, ))
))
6
7 AFFIDAVIT OF CUSTODIAN OF RECORDS
8 OF BUSINESS
FOR THE AUTHENTICATION 0F BUSINESS RECORDS
9 Before me,
Before me, the undersigned authority,
authority, on this day personally appeared DR.
LOU SAUCEDO,
LOU SAUCEDO, JR.,
JR., D.C.,
D.C., who,
who, being by
by me duly sworn,
sworn, deposed as follows:
10
10
My name
My name is
is DR.
DR. LOU SAUCEDO,
SAUCEDO, JR.,
JR., D.C.,
D.C., II am of sound mind, capable of
making this
making this affidavit,
affidavit, and personally acquainted with the
the facts herein
11
ll
stated:
stated:
12
12 I am
I am the
the custodian
custodian of
of healthcare treatment records for LONE STAR RADIOLOGY,
and II am
and am familiar
familiar with the manner in which such records are
are created and
13
13 maintained by
maintained by virtue of my
my duties and responsibilities.
responsibilities.
14
l4 Attached hereto are _05_ pages of records from 06/28/2019, pertaining to
ALARCON. These are exact duplicates of the
EMMA ALARCON. the original records.
15
15
It is
It is the
the regular practice of LONE STAR RADIOLOGY
RADIOLOGY to make
make this type of
record at
record at or
or near
near time of each act,
act, event,
event, condition, opinion, or diagnosis
16
16 set forth
forth in
in the
the record.
record. It
It is
is the regular practice of LONE
set LONE STAR RADIOLOGY
for this type
for this type of of record to be made by,
by, or from information transmitted by,
by,
17
17 persons with knowledge of the matters set forth in them.
persons
18
l8 It is
It is the
the regular practice of LONE STAR RADIOLOGY to keep
keep this type of
record in
record in the
the course
course of its
its regularly conducted
conducted business
business activity, an
anft-'i; is
19 the regular
the regular practice of LONE STAR RADIOLOGY to make the
the records.
records
19
M,
20 c^Affl^nt(Custodian of Records)
(:3ffi§;t(Custodian of Records)
21
21
22
22
m
SWORN TO AND SUBSCRIBED before me on the M- day ofpf
AL npkl 0 F
, 2020.
Q=iaELzQiEtr:=SZL¢QiziElfilé:l___
23
23 Notary PPublic,
Notary Texas
lic, State of Texa
T
Notary's printed name and
24
commission expires:05-13-23
25
LILY SALINAS
LlYSAUNAS
My Notary
My Notary ID
ID ## 130225380
130225380
■
Expires
Expires May 13,
May 13,2023
2023
.
.1.“ *T... t
)
) No:
Cause No:
1 )
)
)
)
2 Plamnff,
n u
Plaintiff, )
) m
IN THE DISTRICT COURT or
OF
)
)
3 vs. )) COUNTY, TEXAS
DALLAS COUNTY,
))
4 . ) JUDICIAL
) JUDICIAL DISTRICT
))
5 Defendant, ))
6
7 AFFIDAVIT REGARDING MEDICAL EXPENSES
8 (Tex. Civ. Prac. s& Rem. Code,
(Tex. Code Sec. 18.002(b-1)
Sec.
9
Before me,
Before me, the undersigned authority,
authority, on this day personally appeared DR.
10
10 LOU SAUCEDO,
LOU SAUCEDO, JR.,
JR., D.C.,
D.C., who,
who, being by
by me
me duly sworn,
sworn, deposed as follows:
11
ll
My name
My name is
is DR.
DR. LOU SAUCEDO,
SAUCEDO, JR.,
JR., D.C.,
D.C., II am
am of
of sound
sound mind, capable of
making this affidavit,
making this affidavit, and personally acquainted with the facts herein
stated:
12
12
II am the custodian of
of billing records
records for
for LONE STAR RADIOLOGY.
RADIOLOGY, Attached to
13
13 this affidavit are
this are records that provide an itemized
itemized statement of the
charge(s) for the service(s) that LONE STAR RADIOLOGY provided
service(s)and charge(s)
14
l4 to EMMA
to EMMA ALARCON
ALARCON from 06/28/2019. The attached records are
are aa part of this
affidavit.
15
15
The attached
The attached records are kept by
by LONE STAR RADIOLOGY
RADIOLOGY in the regular course
of business,
of business, and it
it was the regular course of business
business of LONE STAR RADIOLOGY
16
16
for an
for an employee
employee or
or representative of LONE STAR RADIOLOGY
RADIOLOGY with knowledge of
the service provided,
the provided, to make the record or to transmit
transmit information to be
17
l7 included in
included in the record.
record. The records
records were made in
in the regular course of
business at
business at or near the time or reasonably soon after the time the service
18
18 was provided. The
was The records are a duplicate of the original.
19
l9 amount charged for the
The services provided were necessary and the amount
services was reasonable at the time and place that
services that the services were
20 provided.
20
The total amount paid for the services was $0.00 and the amount currently
The
21
21 unpaid but
unpaid but which LONE STAR RADIOLOGY has a right
right to be paid after any
adjustments or credits is
adjustments or is $346.00. This amount may
may include
include a Records Summary
22
22 Report fee
Raport fee of
of $150.00.
23
23
24
24
AFFIANT(Custodian Of Records)
25
1
SWORN TO AND SUBSCRIBED before me on the day of
I , 2020.
Public,State
Notary Publ Te>
c, State of Texaa
2
Notary's printed name and
Notary’s
commission expires:05-13-2023
commission
3
SALINAS
LILY SALINAS
LILY
4 : Notary ID
My Now # 130225380
ID # 130225380
My
i! %;.?v ^Pir8S
Expires May 13,2023
May 13, 2023
5 •**»
6
7
8
9
10
10
11
11
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
1 )
) Cause No.:
))
2 Plaintiff,
Plaintiff, )
)
)
) DISTRICT COURT
IN THE DISTRICT
3 vs.
V8. )
) DALLAS COUNTY,
COUNTY, TEXAS
4 )
)
vvvvvv
5 Defendant, )
)
6
7 AFFIDAVIT OF CUSTODIAN OF RECORDS
8 FOR THE AUTHENTICATION OF BUSINESS RECORDS
9 Before ma,
Before me, the undersigned authority,
authority, on this day personally appeared DR.
LOU SAUCEDO,
LOU SAUCEDO, JR.,
JR., D.C.,
D.C., who,
who, being by
by me duly sworn,
sworn, deposed as follows:
10
10
My name
My name is
is DR.
DR. LOU SAUCEDO,
SAUCEDO, JR.,
JR., D.C.,
D.C., II am
am of
of sound
sound mind, capable of
making this
making this affidavit,
affidavit, and personally
personally acquainted with
with the
the facts herein
11
11
stated:
12
12 I
I the custodian of healthcare treatment records
am the records for
for WHITE ROCK OPEN AIR
MRI, and II am
MRI, am familiar
familiar with the manner in which such records are created and
13
l3 maintained by
maintained by virtue of my
my duties and responsibilities.
14
14 Attached hereto
Attached hereto are _08_ pages of records
records from 07/15/2019,
07/15/2019, pertaining to
EMMA ALARCON.
EMMA ALARCON. These are exact duplicates of the original records.
15
15
It is
It is the regular practice of WHITE ROCK OPEN
OPEN AIR
AIR MRI
MRI to make this type of
record at
record at or
or near
near time of each act,
act, event,
event, condition,
condition, opinion, or diagnosis
16
16 set forth
set forth in
in the
the record.
record. It
It is
is the regular practice
practice of
of WHITE ROCK OPEN AIR
MRI for
MRI for this
this type
type of
of record to be made by,
by, or from
from information transmitted
17
l7 by, persons
by, persons with knowledge of the matters set forth in in them.
18
l8 It is
It is the regular
regular practice of WHITE ROCK OPEN
OPEN AIR MRI
MRI to keep this type of
record in the course of its regularly conducted business activity, it is
19 the regular practice of WHITE ROCK OPEN AIR MRI to make the recpxd s.
l9
20
20 Affiant(Custodian of Records)
21
21
22
22
SWORN TO AND SUBSCRIBED before me on the day of o , 2020.
23
23 Public,
Notary Pub ic, State of Texas
Notary's printed name and
Notary's
24
24 commission expires:05-13-23
expires:05-13-23
25
25
I /Cftl My Notary
LILY SALINAS
LILY SALINAS
ID # 130225380
m a 130225380
‘ fW Expires May
May 13'
13,2023
2°23
Expfires -J'
) Cause No:
) No:
1 ))
))
2 Plaintiff,
n u
PlamtJ-ff. )
) IN THE
IN THE DISTRICT COURT or
OF
))
3 vs .
vs. )
) DALLAS COUNTY,
COUNTY, TEXAS
))
4 r
)
) JUDICIAL DISTRICT
))
5 Defendant,
Defendant, ))
6
7 AFFIDAVIT REGARDING MEDICAL EXPENSES
8 (Tex. Civ.
(Tex. Civ. Prac.
Prac. s& Rem.
Rem. Code,
Code, Sec.
Sec. 18.002(b-1)
18.002(b-l)
9
Before ma,
Before me, the undersigned authority,
authority, on this
this day
day personally appeared DR.
10
10 LOU SAUCEDO,
LOU SAUCEDO, JR.,
JR., D.C.,
D.C., who,
who, being by
by me duly sworn,
sworn, deposed
deposed as follows:
11
ll
My name
My name is
is DR.
DR. LOU
LOU SAUCEDO,
SAUCEDO, JR.,
JR., D.C.,
D.C., II am of sound mind,
mind, capable of
making this affidavit,
making this affidavit, and personally acquainted
acquainted with
with the facts
facts herein
stated:
12
12
I am the
I the custodian of billing records for WHITE ROCK
ROCK OPEN
OPEN AIR MRI.
13
l3 Attached to
Attached to this
this affidavit
affidavit are records that provide an itemized statement of
the sarvice(s)and
the service(s)and charge(s)
charge(s) for the service(s)
service(s) that
that WHITE ROCK OPEN AIR MRI
14
l4 provided to EMMA
provided EMMA ALARCON from 07/15/2019.
07/15/2019. The attached records are a part of
this affidavit.
this
15
15
The attached
The attached records
records are kept by
by WHITE ROCK OPEN AIR MRI in the regular
course of
course of business,
business, and it
it was the regular course of business of WHITE ROCK
16
16
for an
OPEN AIR MRI for an employee or representative
representative of
of WHITE ROCK OPEN AIR MRI
with knowledge
with knowledge of
of the
the service provided,
provided, to make the
the record
record or
or to transmit
17
17 information to
information to be included in the record.
record. The records
records were
were made in the
regular course of business at
regular at or near the time or
or reasonably soon after the
18
18 time the service
time the service was provided. The records are aa duplicate
duplicate of the original.
19
19 The services
The services provided were necessary and the amount charged for the
services was
services was reasonable at
at the time and place that the
the services were
provided.
providad.
20
20
The total
The total amount
amount paid for the services
services was
was $0.00
$0.00 and the
the amount currently
21
21 unpaid but
unpaid but which
which WHITE
WHITE ROCK OPEN AIR MRI has aa right to be paid after any
adjustments or credits
adjustments credits is
is $5,995.00.
$5,995.00. This
This amount may include a Records
22
22 Summary Report fee of $150.00.
23
23
24
24
AFFIANT(Custodian Of Records)
Preview
FILED 8/6/2020 1:09 PM FELICIA PITRE DISTRICT CLERK Contains Sensitive Data DALLAS CO., TEXAS Dorothy Strogen DEPUTY CAUSE NO. DC-20-04620 ABIGAIL M. ARROYO and EMMA § IN THE DISTRICT COURT R. ALARCON § § V. § 160TH JUDICIAL DISTRICT § VICTORIA C. HUFFSTUTLER § § DALLAS COUNTY, TEXAS § DEFENDANT’S COUNTER-AFFIDAVIT PURSUANT TO SECTION 18.001 OF THE TEXAS CIVIL PRACTICES & REMEDIES CODE RE: MEDICAL & BILLING AFFIDAVITS STATE OF TEXAS § § KNOWN ALL MEN BY THESE PRESENTS: COUNTY OF DALLAS § BEFORE ME, the undersigned authority, a notary public in and for the State of Texas, 0n this day personally appeared Lennard A. Nadalo, M.D., F.A.C.R. who being by me first duly sworn upon his oath, deposed as stated: “My name Lennard A. Nadalo, M.D., F.A.C.R. I am a licensed Medical Doctor in is Texas and an ABR Board Certified Radiologist. I also hold special certification in Illinois. I am Neuroradiology granted me by the American Board 0f Radiology. I have a BS Summa cum laude from North Park University, Chicago, Illinois and a M.D. with Honors in Pathology and Clinical Diagnosis from Northwestern University, Chicago, Illinois. I currently practice Diagnostic Radiology and Neuroradiology in Methodist Dallas Medical Center, Methodist Charlton Medical Center, Methodist McKinney Hospital, Crescent Medical Center Lancaster, First Baptist Medical Center and Very Special Images, PLLC. I am currently on the Methodist Dallas Medical Center and Methodist Charlton Medical Center Tumor Board. I also have a fellowship in the American College of Radiology, F.A.C.R. (See Curriculum Vitae, attached hereto as Exhibit 'A,’ incorporated herein for all purposes.) I am over 18 years of age, 0f sound mind, and make this affidavit upon my best information and belief. I state that I am qualified by knowledge, skill, experience, training, education and other expertise to make the statements contained in this affidavit and I am fillly competent to testify t0 the matters stated herein. My Texas license is E5417. I have treated numerous patients in the field of diagnostic radiology. I practice Diagnostic Radiology and Neuroradiology in multiple hospitals including a hospital serving a trauma center. I have performed numerous record reviews and served as an expert Witness for both plaintiffs and defendants in Dallas County, Collin County, Tarrant County and throughout the State 0f Texas. I am familiar With reasonable and customary charges for evaluation and treatment thereof in Dallas County and throughout the State 0f Texas.” COUNTER-AFFIDAVIT OF Lennard A. Nadalo, MD, FACR Page 1 10000.0808/emonsivais “This counter-affidavit is made pursuant to §18.001 of the TEXAS CIVIL PRACTICES & REMEDIES CODE and is made in response t0 the following affidavits and/or records pertaining t0 Plaintiff Emma Alarcon which are attached hereto as Exhibit ‘B’: 1. Lone Star Radiology; and 2. White Rock Open Air MRI. “Such affidavits state as a purported fact that the services outlined 0n attachments thereto were necessary and that the charges for said services were reasonable; however, I have reviewed the medical and billing records attached t0 the above-referenced affidavits and it is my opinion, based 0n my training, experience, and expertise, that the health care treatment and numerous procedures and charges, as indicated in my report dated August 4, 2020, are neither reasonable, necessary nor justified by the condition as described by said medical reports. Please see the true and correct copy of the report which is attached to this counter—affidavit and incorporated herein by reference as Exhibit ‘C’.” Further Affiant sayeth not. %{W/¢ MM éfi/Wr Lennard A. Nadalo, M.D., F.A.C.R. STATE 0F TEXAS § § COUNTY 0F DALLAS § SWORN TO AND SUBSCRIBED before me by Lennard A. Nadalo, M.D., F.A.C.R. on this é day of Augue'f , 2020, to certify which witness my hand and official seal. v" '04 CHROSTOPHER O FECHT / /\ : F Notary ID 8131647770 l H My Commission Expires mow Juwmozz NOTARY PU IC-STATE WTEXAS COUNTER-AFFIDAVIT OF Lennard A. Nadalo, MD, FACR Page 2 10000.0808/em0nsivais EXHIBIT “A” PERSONAL: NAME: Lennard Albert Nadalo, MD, FACR HOME ADDRESS: 6443 Riverview Lane Dallas, Texas 75248 HOME TELEPHONE: 469-248-2507 CELL PHONE: 972-998-6825 E-MAIL: lennadalo@lennadalo.com HOME FAX: 214-723-5957 HOME OFFICE: 6443 Riverview Lane Dallas, Texas 75248 VERY SPECIAL IMAGES: 6443 Riverview Lane Dallas, Texas 75248 GROUP PRACTICE: Radiological Consultants of North Texas Administrative Office 816 W. Cannon St. Fort Worth, Texas 76104 OFFICE PHONE: 817-321-0499 OFFICE FAX: 866-711-8151 EDUCATION: COLLEGE: North Park University 5125 N. Spaulding Ave. Chicago, Illinois 60625 Sept., 1965 - June, 1969 Summa cum laude, BA, Natural Sciences MEDICAL SCHOOL: Northwestern University The Feinberg School of Medicine Morton Building 1-606 303 East Chicago Avenue Chicago, Illinois 60611-3008 September, 1969 - June, 1973 MD, with Honors in Pathology and Clinical Diagnosis Awarded on June 16, 1973 Revised July 13, 2020 Lennard A. Nadalo MD FACR POST GRADUATE TRAINING AND EXPERIENCE: INTERNSHIP: Madigan Army Medical Center Fort Lewis Tacoma, WA 98431 USA 253- 968-1110 July 1, 1973 - June 30, 1974 RESIDENCY: Diagnostic Radiology San Antonio Military Medical Center (Brooke Army Medical Center) 3851 Roger Brooke Drive Fort Sam Houston, Texas 78234 (210) 916-4141/3400 July 1, 1974 - June 30, 1977 Armed Forces Institute of Pathology Washington, D.C., 20012 May 10 - July 2, 1976 STAFF POSITION: Diagnostic Radiology Tripler Army Medical Center Jarrett White Road (808) 433-6661 Honolulu, HI 96859-5000 July 1, 1977 – July 1, 1979. General diagnostic radiology, angiography, pediatric radiology, ultrasound FELLOWSHIP: Neuroradiology and Interventional Radiographic Procedures Walter Reed National Military Medical Center (Walter Reed Army Medical Center) Washington, D.C., 20012 July 1, 1979 - June 30, 1980 INSTRUCTOR: Department of Radiology Uniformed Services University of the Health Sciences School of Medicine Bethesda, Maryland 1980 - 1981 STAFF POSITION: Chief, Section of Neuroradiology and Special Radiographic Procedures Walter Reed Army Medical Center Washington, D.C., 20012 July 1, 1980 - July 1, 1982 2 Revised July 13, 2020 Lennard A. Nadalo MD FACR Neuroradiology, myelography, interventional radiology, head of section, director of Neuroradiology and Angiography Fellowship. ASSISTANT PROFESSOR: Department of Radiology Uniformed Services University of the Health Sciences School of Medicine Bethesda, Maryland 1981 - 1982 LECTURER: The Army Forces Institute of Pathology. Washington, D.C. 1980 – 1982. MILITARY SERVICE: United State Army, 1972 – 1982. Honorable Discharge with the rank of Lt. Col. US Army Medical Corp. Special Training in the management of Nuclear Radiological Disasters. Radiological Emergency Management Team. (REM Team) INSTRUCTOR: Physician Associate Program Department of Family and Preventative Medicine The University of Oklahoma Health Science Center College of Medicine 900 Northeast 10th Street Post Office Box 26901 Oklahoma City, Oklahoma 73190 (405) 271-2058 2002 – 2003. LECTURER: University of Texas Arlington Graduate Program, Dept. of Advanced Practice Nursing UT Arlington College of Nursing 2010 – 2015. CLINICAL PROFESSOR: Department of Radiology University of Texas Health Science Center at Dallas Southwestern Medical School 5323 Harry Hines Blvd. 3 Revised July 13, 2020 Lennard A. Nadalo MD FACR Dallas, Texas 75390 1982 – 2014. LECTURER: Family Practice Residency Program Methodist Charlton Medical Center Internal Medicine Residency Program Methodist Dallas Medical Center Current CURRENT PROFESSIONAL ACTIVITIES: CURRENT POSITION: Active Staff Member Neuroradiology, & Diagnostic Radiology Methodist Hospitals of Dallas 1441 North Beckley PO Box 655999 Dallas, TX 75265-5999 Department of Radiology Telephone: 214/947-2600 FAX: 214-947-2652 1982 – Present. Radiological Consultants of North Texas Administrative Office 816 W. Cannon St. Fort Worth, Texas 76104 OFFICE PHONE: 817-321-0499 April 1, 2016 to present. Very Special Images, P.L.L.C. 6443 Riverview Lane Dallas, Texas 75248 FAX: 214-723-5957 EIN: 26-4680563 HOSPITAL APPOINTMENTS: Methodist Dallas Medical Center, 1441 N. Beckley Ave. Dallas, Texas 75203. 214-8181. Teaching and Referral Hospital. Methodist Charlton Medical Center, 3500 Wheatland Rd. Dallas, Texas 75237. 214-947-7777. Teaching and Full-Service Acute Care Hospital. Methodist Mansfield Medical Center, 2700 E. Broad Street, Mansfield, TX 76063. (682)242-2000. Full-Service Acute Care Hospital. Methodist McKinney Hospital, 8000 W. Eldorado Parkway, McKinney, Texas 75070. Specialty Hospital. 4 Revised July 13, 2020 Lennard A. Nadalo MD FACR CURRENT PROFESSIONAL ACTIVITY My professional activities are centered in the areas of DIAGNOSTIC RADIOLOGY, NEURORADIOLOGY, ULTRASOUND, CROSS SECTIONAL BODY IMAGING and ORTHOPEDIC IMAGING. Ienjoy teaching with an emphasis upon neuroradiology, US, CT, and MRI. | provide interpretation of diagnostic radiographic images including x—rays, MRI, CT, US and NM. read | cerebral sonography, duplex sonography, and diagnostic sonography. lfully participate in the interpretation of US, MRI and CT of a wide variety of oncologic, traumatic, infectious and orthopedic conditions. support various | clinical practices including neonatal ICU, ER, neuro ICU, cancer treatment, organ transplantation and trauma. OFFICES and COMMITTEES Cancer Committee, Methodist Dallas Medical Center, (2011— 2016) Presenter: Methodist Dallas Medical Center, Tumor Board, Presenter: Methodist Charlton Medical Center Tumor Board (Current) Co-Medical Director, Envision Imaging of Allen (2004 — 2011) Endovascular Committee, Clinical Outcomes Management (2004 — 2006) Institutional Review Board, Methodist Medical Center. (1982-2003) President of the Medical Staff, Methodist Medical Center. (1997-1998). Board of Trustees, Methodist Medical Center. (1996—1999), Chairman, Department of Radiology, Methodist Hospitals of Dallas (1998-2000) President, Radiological Consultants Association (1998-2000) SPECIAL INTERESTS WebMD Author: Cervical spine trauma, Acute Stroke Peer reviewer Journal of Computerized Axial Tomography (JCAT) (Current) Author: eMedicine.com, Medscape.com. WebMD.com. CERTIFICATION: MEDICAL BOARDS: American Board of Radiology (Diagnostic) December 7, 1977 Neuroradiology, CAQ, ABR (Current) FLEX, December, 1975 (33235) LICENSURE: State of Texas (E 5417) (February 28, 2021). DEA Registration (AN8888058) (Current) INSURANCE: Medicare Provider (M367) Group Medicaid Provider 2000M3670 NPI #1699758276. TMLT 1-400900 ProCPR Adult, , Child and Infant: 158039726386604 MEDICAL ASSOCIATION MEMBERSHIP: American College of Radiology / American Roentgen Ray Society American Society of Neuroradiology, Senior Member Revised July 13, 2020 Lennard A. Nadalo MD FACR American Society of Functional Neuroradiology American Society of Pediatric Neuroradiology American Society of Spinal Radiology Radiological Society of North America Texas Radiological Society AWARDS AND SPECIAL HONORS: Fellowship in the American College of Radiology, FACR, May 15, 2011. Third Annual General Graves B. Erskin Award: "Outstanding Physician in Fellowship Training (Angiography and Neuroradiology)" Walter Reed Army Medical Center 1979-1980. President Medical Staff Methodist Medical Center, 1998-1999. Chairman Department of Radiology Methodist Hospitals of Dallas, 1998-2000 President Radiological Consultants Association, 1998-2000 RECENT POST-GRADUATE EDUCATION: American College of Radiology, Fellow 70 CME Hours January 1, 2019 – July 13, 2020. American Board of Radiology, MOC, CAQ, Neuroradiology is current. ASNR CME including SAMs are current. “Case in Point,” ACR, January 1, 2019 – July 13, 2020 36 hours, CME Category 1. Adult / Child / Infant CPR and AED Certification for Health Care Providers (BLS) following the National Cognitive Evaluation in accordance with the ProTrainings curriculum and the American Heart Association® guidelines. Current. Manuscript Reviews, JCAT, (102). PUBLICATIONS AND INVITED PRESENTATIONS: I have served as a Clinical Professor of Radiology at the University of Texas Health Science Center at Dallas. I have presented multiple one-hour conferences concerning Special Imaging including Spiral CT, MRI, Sonography, and Nuclear Medicine correlation, Neuroradiology and Interventional Radiology to the Residents in the Department of Radiology. Current and Recent Projects: Introduction to Pulmonary Radiology, Lectures to Internal Medicine Department, 2017-2020. Nadalo LA, Hunter LK. Brain Abscess Imaging. Medscape Drugs & Diseases. Updated August 13, 2017. Available at: http://emedicine.medscape.com/article/336829. Nadalo LA. Carotid Artery Stenosis Imaging. Medscape Drugs & Diseases. Available at: http://emedicine.medscape.com/article/417524. 6 Revised July 13, 2020 Lennard A. Nadalo MD FACR Nadalo LA, Dickerman RM, Slonim SM. Imaging in Kidney Transplantation Complications. Medscape Drugs & Diseases. Updated 2019. Available at: http://emedicine.medscape.com/artic|e/378801. Nadalo LA. Lumbar Spine Trauma Imaging. Medscape Drugs & Diseases. Available at: http://emedicine.medscape.com/articIe/398102. Nadalo LA, Jones K. Rib Fracture Imaging. Medscape Drugs & Diseases. Available at: http://emedicine.medscape.com/articIe/395172. Nadalo LA. Spinal Stenosis Imaging. Medscape Drugs & Diseases. Available at: http://emedicine.medscape.com/artic|e/344171. Nadalo LA. Thoracic Spinal Trauma Imaging. Medscape Drugs & Diseases. Updated January 23, 2019. Available at: http://emedicine.medscape.com/artic|e/397896. Introduction to Neuroradiology, Lecture to Internal Medicine Residents, 4/20/2017. The Imaging of Stroke, Prevention, Early Detection and Follow-Up, Pathways of Stroke, updated, Lecture to Internal Medicine Residents 2017. Acute Stroke, Web MD Cervical Spine Trauma, Web MD Gastrointestinal Fluoroscopic Studies, 4t“ Annual Symposium for Health Professionals. Methodist Dallas Medical Center Department of Radiology. 11/7/2015. Imaging of Spinal Stenosis, Medscape, 4/20/2017. Spinal Stenosis Imaging emedicine.medscape.com/artic|e/344171-overview - Author: Lennard A Nadalo, MD; Chief Editor: James G Smirniotopoulos, MD more... Updated: 2017. EXHIBIT “B” f* 1 , ) ) Cause No.: )) 2 Plaintiff, plaintiff, )) ) ) IN THE DISTRICT COURT 3 vs. vs. )) ) ) DALLAS COUNTY, COUNTY, TEXAS 4 )) )) 5 Defendant, Defendant, )) )) 6 7 AFFIDAVIT OF CUSTODIAN OF RECORDS 8 OF BUSINESS FOR THE AUTHENTICATION 0F BUSINESS RECORDS 9 Before me, Before me, the undersigned authority, authority, on this day personally appeared DR. LOU SAUCEDO, LOU SAUCEDO, JR., JR., D.C., D.C., who, who, being by by me duly sworn, sworn, deposed as follows: 10 10 My name My name is is DR. DR. LOU SAUCEDO, SAUCEDO, JR., JR., D.C., D.C., II am of sound mind, capable of making this making this affidavit, affidavit, and personally acquainted with the the facts herein 11 ll stated: stated: 12 12 I am I am the the custodian custodian of of healthcare treatment records for LONE STAR RADIOLOGY, and II am and am familiar familiar with the manner in which such records are are created and 13 13 maintained by maintained by virtue of my my duties and responsibilities. responsibilities. 14 l4 Attached hereto are _05_ pages of records from 06/28/2019, pertaining to ALARCON. These are exact duplicates of the EMMA ALARCON. the original records. 15 15 It is It is the the regular practice of LONE STAR RADIOLOGY RADIOLOGY to make make this type of record at record at or or near near time of each act, act, event, event, condition, opinion, or diagnosis 16 16 set forth forth in in the the record. record. It It is is the regular practice of LONE set LONE STAR RADIOLOGY for this type for this type of of record to be made by, by, or from information transmitted by, by, 17 17 persons with knowledge of the matters set forth in them. persons 18 l8 It is It is the the regular practice of LONE STAR RADIOLOGY to keep keep this type of record in record in the the course course of its its regularly conducted conducted business business activity, an anft-'i; is 19 the regular the regular practice of LONE STAR RADIOLOGY to make the the records. records 19 M, 20 c^Affl^nt(Custodian of Records) (:3ffi§;t(Custodian of Records) 21 21 22 22 m SWORN TO AND SUBSCRIBED before me on the M- day ofpf AL npkl 0 F , 2020. Q=iaELzQiEtr:=SZL¢QiziElfilé:l___ 23 23 Notary PPublic, Notary Texas lic, State of Texa T Notary's printed name and 24 commission expires:05-13-23 25 LILY SALINAS LlYSAUNAS My Notary My Notary ID ID ## 130225380 130225380 ■ Expires Expires May 13, May 13,2023 2023 . .1.“ *T... t ) ) No: Cause No: 1 ) ) ) ) 2 Plamnff, n u Plaintiff, ) ) m IN THE DISTRICT COURT or OF ) ) 3 vs. )) COUNTY, TEXAS DALLAS COUNTY, )) 4 . ) JUDICIAL ) JUDICIAL DISTRICT )) 5 Defendant, )) 6 7 AFFIDAVIT REGARDING MEDICAL EXPENSES 8 (Tex. Civ. Prac. s& Rem. Code, (Tex. Code Sec. 18.002(b-1) Sec. 9 Before me, Before me, the undersigned authority, authority, on this day personally appeared DR. 10 10 LOU SAUCEDO, LOU SAUCEDO, JR., JR., D.C., D.C., who, who, being by by me me duly sworn, sworn, deposed as follows: 11 ll My name My name is is DR. DR. LOU SAUCEDO, SAUCEDO, JR., JR., D.C., D.C., II am am of of sound sound mind, capable of making this affidavit, making this affidavit, and personally acquainted with the facts herein stated: 12 12 II am the custodian of of billing records records for for LONE STAR RADIOLOGY. RADIOLOGY, Attached to 13 13 this affidavit are this are records that provide an itemized itemized statement of the charge(s) for the service(s) that LONE STAR RADIOLOGY provided service(s)and charge(s) 14 l4 to EMMA to EMMA ALARCON ALARCON from 06/28/2019. The attached records are are aa part of this affidavit. 15 15 The attached The attached records are kept by by LONE STAR RADIOLOGY RADIOLOGY in the regular course of business, of business, and it it was the regular course of business business of LONE STAR RADIOLOGY 16 16 for an for an employee employee or or representative of LONE STAR RADIOLOGY RADIOLOGY with knowledge of the service provided, the provided, to make the record or to transmit transmit information to be 17 l7 included in included in the record. record. The records records were made in in the regular course of business at business at or near the time or reasonably soon after the time the service 18 18 was provided. The was The records are a duplicate of the original. 19 l9 amount charged for the The services provided were necessary and the amount services was reasonable at the time and place that services that the services were 20 provided. 20 The total amount paid for the services was $0.00 and the amount currently The 21 21 unpaid but unpaid but which LONE STAR RADIOLOGY has a right right to be paid after any adjustments or credits is adjustments or is $346.00. This amount may may include include a Records Summary 22 22 Report fee Raport fee of of $150.00. 23 23 24 24 AFFIANT(Custodian Of Records) 25 1 SWORN TO AND SUBSCRIBED before me on the day of I , 2020. Public,State Notary Publ Te> c, State of Texaa 2 Notary's printed name and Notary’s commission expires:05-13-2023 commission 3 SALINAS LILY SALINAS LILY 4 : Notary ID My Now # 130225380 ID # 130225380 My i! %;.?v ^Pir8S Expires May 13,2023 May 13, 2023 5 •**» 6 7 8 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 1 ) ) Cause No.: )) 2 Plaintiff, Plaintiff, ) ) ) ) DISTRICT COURT IN THE DISTRICT 3 vs. V8. ) ) DALLAS COUNTY, COUNTY, TEXAS 4 ) ) vvvvvv 5 Defendant, ) ) 6 7 AFFIDAVIT OF CUSTODIAN OF RECORDS 8 FOR THE AUTHENTICATION OF BUSINESS RECORDS 9 Before ma, Before me, the undersigned authority, authority, on this day personally appeared DR. LOU SAUCEDO, LOU SAUCEDO, JR., JR., D.C., D.C., who, who, being by by me duly sworn, sworn, deposed as follows: 10 10 My name My name is is DR. DR. LOU SAUCEDO, SAUCEDO, JR., JR., D.C., D.C., II am am of of sound sound mind, capable of making this making this affidavit, affidavit, and personally personally acquainted with with the the facts herein 11 11 stated: 12 12 I I the custodian of healthcare treatment records am the records for for WHITE ROCK OPEN AIR MRI, and II am MRI, am familiar familiar with the manner in which such records are created and 13 l3 maintained by maintained by virtue of my my duties and responsibilities. 14 14 Attached hereto Attached hereto are _08_ pages of records records from 07/15/2019, 07/15/2019, pertaining to EMMA ALARCON. EMMA ALARCON. These are exact duplicates of the original records. 15 15 It is It is the regular practice of WHITE ROCK OPEN OPEN AIR AIR MRI MRI to make this type of record at record at or or near near time of each act, act, event, event, condition, condition, opinion, or diagnosis 16 16 set forth set forth in in the the record. record. It It is is the regular practice practice of of WHITE ROCK OPEN AIR MRI for MRI for this this type type of of record to be made by, by, or from from information transmitted 17 l7 by, persons by, persons with knowledge of the matters set forth in in them. 18 l8 It is It is the regular regular practice of WHITE ROCK OPEN OPEN AIR MRI MRI to keep this type of record in the course of its regularly conducted business activity, it is 19 the regular practice of WHITE ROCK OPEN AIR MRI to make the recpxd s. l9 20 20 Affiant(Custodian of Records) 21 21 22 22 SWORN TO AND SUBSCRIBED before me on the day of o , 2020. 23 23 Public, Notary Pub ic, State of Texas Notary's printed name and Notary's 24 24 commission expires:05-13-23 expires:05-13-23 25 25 I /Cftl My Notary LILY SALINAS LILY SALINAS ID # 130225380 m a 130225380 ‘ fW Expires May May 13' 13,2023 2°23 Expfires -J' ) Cause No: ) No: 1 )) )) 2 Plaintiff, n u PlamtJ-ff. ) ) IN THE IN THE DISTRICT COURT or OF )) 3 vs . vs. ) ) DALLAS COUNTY, COUNTY, TEXAS )) 4 r ) ) JUDICIAL DISTRICT )) 5 Defendant, Defendant, )) 6 7 AFFIDAVIT REGARDING MEDICAL EXPENSES 8 (Tex. Civ. (Tex. Civ. Prac. Prac. s& Rem. Rem. Code, Code, Sec. Sec. 18.002(b-1) 18.002(b-l) 9 Before ma, Before me, the undersigned authority, authority, on this this day day personally appeared DR. 10 10 LOU SAUCEDO, LOU SAUCEDO, JR., JR., D.C., D.C., who, who, being by by me duly sworn, sworn, deposed deposed as follows: 11 ll My name My name is is DR. DR. LOU LOU SAUCEDO, SAUCEDO, JR., JR., D.C., D.C., II am of sound mind, mind, capable of making this affidavit, making this affidavit, and personally acquainted acquainted with with the facts facts herein stated: 12 12 I am the I the custodian of billing records for WHITE ROCK ROCK OPEN OPEN AIR MRI. 13 l3 Attached to Attached to this this affidavit affidavit are records that provide an itemized statement of the sarvice(s)and the service(s)and charge(s) charge(s) for the service(s) service(s) that that WHITE ROCK OPEN AIR MRI 14 l4 provided to EMMA provided EMMA ALARCON from 07/15/2019. 07/15/2019. The attached records are a part of this affidavit. this 15 15 The attached The attached records records are kept by by WHITE ROCK OPEN AIR MRI in the regular course of course of business, business, and it it was the regular course of business of WHITE ROCK 16 16 for an OPEN AIR MRI for an employee or representative representative of of WHITE ROCK OPEN AIR MRI with knowledge with knowledge of of the the service provided, provided, to make the the record record or or to transmit 17 17 information to information to be included in the record. record. The records records were were made in the regular course of business at regular at or near the time or or reasonably soon after the 18 18 time the service time the service was provided. The records are aa duplicate duplicate of the original. 19 19 The services The services provided were necessary and the amount charged for the services was services was reasonable at at the time and place that the the services were provided. providad. 20 20 The total The total amount amount paid for the services services was was $0.00 $0.00 and the the amount currently 21 21 unpaid but unpaid but which which WHITE WHITE ROCK OPEN AIR MRI has aa right to be paid after any adjustments or credits adjustments credits is is $5,995.00. $5,995.00. This This amount may include a Records 22 22 Summary Report fee of $150.00. 23 23 24 24 AFFIANT(Custodian Of Records)