Preview
FILED
8/10/2023 2:38 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
No. DC-23—01657 Debra Clark DEPUTY
HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT 0F
individually and as next friends of §
L.F.B., a Minor §
§ DALLAS COUNTY, TEXAS
vs. §
§
D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT
NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff by and through their attorney(s) of record: Carrie Vine, Charles Clayton Miller, Les Weisbrod and Matthew Jay
Adair
To other party/parties by and through their attorney(s) of record: Carlos Mattioli, Casey L. Cashion, Cory Matthew Sutker,
Elizabeth D. Alvarado, Jon W. Stephenson and Yvette Holloway
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written
questions will be taken of Custodian of Records for:
Integrated Genetics (Medical Records)
2000 Vivigen Way, Santa Fe, NM 87505
before a Notary Public for Lexitas
13101 Northwest Freeway, Suite 330
Houston, TX 77040
713-365-0777 // Fax 713-365-0808
or its designated agent, which deposition with attached questions may be used in evidence upon the trial of the above-styled and
numbered cause pending in the above-named court. Notice is further given that request is hereby made as authorized under Rule
200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be
served upon the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such
record in the possession, custody or control of the said witness, and every such record to which the witness may have access,
pertaining to:
Lyla Brian
and to turn over all such records to the officer authorized to take this deposition so that photographic reproductions of the same
may be made and attached to said deposition.
/s/ Kevin W. Yankowsky
Kevin W. Yankowsky
Norton Rose Fulbright US LLP
1301 McKinney Street, Suite 5100
Houston, TX 77010-3095
713-651-5151 // Fax 713-651-5246
Email: kevin.yankowsky@nortonrosefulbright.com
Attorney for Defendant
State Bar No. 00791967
I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel 0f Record by
hand-delivery, email, facsimile, Federal Express, electronic service, and/0r certified mail (return receipt requested) on this day.
Dated: Auglst 10, 2023 by /s/ Kevin W. Yankowsky
Order No. 64460
No. DC-23-01657
HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT OF
individually and as next friends of §
L.F.B., a Minor §
§ DALLAS COUNTY, TEXAS
VS. §
§
D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: Integrated Genetics
Records Pertaining To: -
Type of Records: Any and all medical records from date of birth to present, including, but not limited to, any new patient
information, medical records, emergency room records, prescriptions, doctor referrals, radiology reports, pathology
reports, insurance records, office notes, office memos, reports, color photographs, audio tapes, video tapes, any and all
type of correspondence, and anything else reduced to writing in the possession, custody or control of the said witness.
Pertaining to [L.F.B.1, DOB —
1. Please state your full name and the name and address of your employer.
Answer:
2. Please state your position and title with the facility identified above.
Answer:
3. Have you accepted the subpoena duces tecum accompanying these Direct Questions?
Answer:
4. D0 you have personal knowledge of the records as outlined in the subpoena duces tecum?
Answer:
5. Are the records outlined in the subpoena duces tecum pertaining to the above-named person in your custody or subject to
your control, supervision or direction?
Answer:
6. Please attach the copies of the records identified in the subpoena duces tecum. Have you complied? If not, why?
Answer:
Order No. 64460.031
7. Are the copies that you attached true and correct copies of all such records?
Answer:
8. Were such records kept in the regular course of business of this facility?
Answer:
9. Was it the regular course of business of this facility for an employee or representative of this facility with knowledge of the
act, event, condition, opinion, or diagnosis that was recorded to make the record or to transmit information thereof to be
included in such record?
Answer:
10. Were the entries on these records made by an employee or representative of this facility at, near the time, or reasonably soon
alter the time of the occurrence that was recorded?
Answer:
ll. Was the method of preparation of these records trustworthy?
Answer:
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared ,
known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first
duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct.
SWORN TO AND SUBSCRIBED before me this day of , 20
Notary Public
Notary’s printed name
My Commission Expires:
Order No. 64460.031
DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS
THE STATE OF TEXAS
To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under Rule 176 of the Texas Rules of
Civil Procedure - GREETINGS -
You are hereby commanded to subpoena and summon the following witness(es): Custodian(s) of Records for
Integrated Genetics
2000 Vivigen Way, Santa Fe, NM 87505
of my designation for
to be and appear before a Notary Public
Lexitas (Phone: 713-365-0777)
13101 Northwest Freeway, Suite 330, Houston TX 77040
or its designated agent on the forthwith day of: INSTANTER at the offlce of the Witness, or any other agreed upon place, and there
remain from day to day and time to time until discharged according to law.
Said above-named Witness is further commanded there, under oath, to make answers of certain written questions to be propounded to the
witness and to bring and produce for inspection and photocopying
Any and all medical records from date 0f birth t0 present, including, but not limited t0, any new patient information, medical
records, emergency room records, prescriptions, doctor referrals, radiology reports, pathology reports, insurance records,
office notes, office memos, reports, color photographs, audio tapes, video tapes, any and all type of correspondence, and
anything else reduced to writing in the possession, custody or control of the said witness. Pertaining to [L.F.B.], DOB:
—
and any other such record in the possession, custody or control of the said witness, and every such record to which the witness may have
access, pertaining to _ at any and all times whatsoever, then and there to give evidence at the instance of the Defendant,
D'Andra Bignham MD, Collom & Carney Clinic Association, represented by Kevin W. Yankowsky, Norton Rose Fulbright US LLP,
Phone Number: 713-651-5151, Address: 1301 McKinney Street, Suite 5100, Houston, TX 77010-3095, Attorney of Record, in that
Certain Cause No. DC-23-01657 pending on the docket of the District Court of the 134th Judicial District of Dallas County, Texas.
This Subpoena is issued under and by virtue of Rule 200 and Notice of Deposition Upon Written Questions on file with the above-
named court, styled
HUNTER BRIAN and SHELBY SCOTT, individually and as next friends of L.F.B., a Minor vs. D'ANDRA D. BINGHAM,
M.D.; COLLOM & CARNEY CLINIC ASSOCIATION; CHRISTUS HEALTH AMC-LA-TEX d/b/a CHRISTUS ST.
MICHAEL HEALTH SYSTEM; CHRISTUS HEALTH; SUSAN ELIZABETH KEENEY, M.D.; and PEDIATRIX MEDICAL
SERVICES, INC. d/b/a PEDIATRIX MEDICAL GROUP OF TEXAS.
WITNESS MY HAND, this 10th day of August, 2023.
STEPHANIE L. HAHT
efli‘l’zfi
ff "gammy Public. Ema of Tam
Comm. Expires 02-24mm
53" WI...
‘55.”?
,.-ߤ
60
fluff...» Notary ID 125593433 NOTHHIY PUBLXC
176.8 Enforcement of Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that
person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena
is served, and may be punished by fine or confinement, or both.
OFFICER'S RETURN
Came to hand this day of , 20 , and executed this the day of , 20 ,
in the following manner: By delivering to the witness ,Via
[ ] Certified Mail, Return Receipt Requested [ ] Federal Express [ ] Fax [ ]Hand Service [ ] Email [ ] Upload, a true copy hereof.
Returned this day of , 20
PROCESS SERVER
Order No. 64460.031
No. DC-23—01657
HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT OF
individually and as next friends of §
L.F.B., a Minor §
§ DALLAS COUNTY, TEXAS
vs. §
§
D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT
COPY ORDER FORM AND WAIVER OF NOTICE
Our cient, Kevn W. Yankowsky, Esq., of Norton Rose Fulbright US LLP, has commissioned Lexitas to obtain documents or things
from the following custodian(s) for use in the above-referenced case.
IF COPIES ARE DESIRED, please indicate below by marking "Y" OR "N" next to the selected location(s).
31 Integrated Genetics (Medical Records)
Fee, per part: $115.00
How would you like your records prepared? { }HaId Copy { }Online download via an e-mailed link
Would you like copies of Affidavit/Declaration of No Records? { }Yes { } No
Would you like copies of radiology films/CD3 (if available)? { }Yes { } No
If you would prefer that we bill the insurance carrier directly, please attach the necessary billing information.
I agree that I and my firm will be responsible for payment of the records ordered via this waiver. I acknowledge that invoices are due
and payable within 30 days of receipt and that actions for collection of services are performable and payable in Harris County, Texas.
_ I DO AGREE TO WAIVE THE NOTICE PERIOD. _ I D0 NOT AGREE TO WAIVE THE NOTICE PERIOD.
Dated:
Signed
Please return to:
Lexitas
13101 Northwest Freeway, Suite 330 Comact and Firm
Houston, TX 77040
Ph: 713-365-0777 // Fax: 713-365-0808
Email: danyelle.j ackson@lexitaslegal.com DeliVel'y Address
Email Address
PLEASE RETURN WITHIN 20 DAYS 0F THE ISSUANCE 0F THIS WAIVER. ANY CANCELLATION 0F THE ABOVE
MUST BE IN WRITING. IF THE RECORDS HAVE ALREADY BEEN COPIED AND FEES INCURRED, THEN BILLING
MLL BE PRORATED ACCORDINGLY.
Order No. 64460
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Envelope ID: 78409608
Filing Code Description: Discovery
Filing Description: NOTICE OF INTENT
Status as of 8/10/2023 2:46 PM CST
Associated Case Party: HUNTER BRIAN
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 8/10/2023 2:38:29 PM SENT
LES WEISBROD lweisbrod@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT
Lori Slywka lorislywka@steedlawfirm.com 8/10/2023 2:38:29 PM SENT
C. Holloway Yvetteholloway@steedlawfirm.com 8/10/2023 2:38:29 PM SENT
Kathy Dorsey kathydorsey@steedlawfirm.com 8/10/2023 2:38:29 PM SENT
Associated Case Party: CHRISTUS HEALTH
Name BarNumber Email TimestampSubmitted Status
Carlos Mattioli cmattioli@smfadlaw.com 8/10/2023 2:38:29 PM SENT
Sherry EKelly skelly@smfadlaw.com 8/10/2023 2:38:29 PM SENT
Elizabeth D. (Lisa)Alvarado lalvarado@smfadlaw.com 8/10/2023 2:38:29 PM SENT
Debra Boyd dboyd@smfadlaw.com 8/10/2023 2:38:29 PM SENT
Associated Case Party: COLLOM & CARNEY CLINIC ASSOCIATION
Name BarNumber Email TimestampSubmitted Status
Liane Hunt liane.hunt@nortonrosefuIbright.com 8/10/2023 2:38:29 PM SENT
Kevin W.Yankowsky kevin.yankowsky@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT
Kim Marcum kim.marcum@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT
Will Martin will.martin@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT
Kristina Williams 24078303 kristina.williams@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT
Bertina York bertina.york@nortonrosefuIbright.com 8/10/2023 2:38:29 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Envelope lD: 78409608
Filing Code Description: Discovery
Filing Description: NOTICE OF INTENT
Status as of 8/10/2023 2:46 PM CST
Associated Case Party: COLLOM & CARNEY CLINIC ASSOCIATION
Kristina Williams kristina.williams@nortonrosefulbrightcom 8/10/2023 2:38:29 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Evelyn Ivy evelyn.ivy@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT
Bertina B.York bertina.york@nortonrosefu|bright.com 8/10/2023 2:38:29 PM SENT
Jon Wayne Stephenson 24041973 jonstephenson@steedlawfirm.com 8/10/2023 2:38:29 PM SENT
Matthew Adair 24084471 madair@millerweisbrod.com 8/10/2023 2:38:29 PM SENT
Charles Clayton Miller 791266 cmiller@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT
Casey Cashion 24103775 caseycashion@steedlawfirm.com 8/10/2023 2:38:29 PM SENT
Ashley Fulks afulks@millerweisbrod.com 8/10/2023 2:38:29 PM SENT
Carrie Lynn Vine 24128671 cvine@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT
Bianca Trejo btrejo@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT
Associated Case Party: SUSANELIZABETHKEENEY
Name BarNumber Email Timestam pSubmitted Status
Betty Goodlow betty.good|ow@cooperscully.com 8/10/2023 2:38:29 PM SENT
Associated Case Party: PEDIATRIX MEDICAL SERVICES, INC.
Name BarNumber Email TimestampSubmitted Status
Cory Sutker cory.sutker@cooperscully.com 8/10/2023 2:38:29 PM SENT
Preview
FILED 8/10/2023 2:38 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS No. DC-23—01657 Debra Clark DEPUTY HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT 0F individually and as next friends of § L.F.B., a Minor § § DALLAS COUNTY, TEXAS vs. § § D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff by and through their attorney(s) of record: Carrie Vine, Charles Clayton Miller, Les Weisbrod and Matthew Jay Adair To other party/parties by and through their attorney(s) of record: Carlos Mattioli, Casey L. Cashion, Cory Matthew Sutker, Elizabeth D. Alvarado, Jon W. Stephenson and Yvette Holloway You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records for: Integrated Genetics (Medical Records) 2000 Vivigen Way, Santa Fe, NM 87505 before a Notary Public for Lexitas 13101 Northwest Freeway, Suite 330 Houston, TX 77040 713-365-0777 // Fax 713-365-0808 or its designated agent, which deposition with attached questions may be used in evidence upon the trial of the above-styled and numbered cause pending in the above-named court. Notice is further given that request is hereby made as authorized under Rule 200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be served upon the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such record in the possession, custody or control of the said witness, and every such record to which the witness may have access, pertaining to: Lyla Brian and to turn over all such records to the officer authorized to take this deposition so that photographic reproductions of the same may be made and attached to said deposition. /s/ Kevin W. Yankowsky Kevin W. Yankowsky Norton Rose Fulbright US LLP 1301 McKinney Street, Suite 5100 Houston, TX 77010-3095 713-651-5151 // Fax 713-651-5246 Email: kevin.yankowsky@nortonrosefulbright.com Attorney for Defendant State Bar No. 00791967 I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel 0f Record by hand-delivery, email, facsimile, Federal Express, electronic service, and/0r certified mail (return receipt requested) on this day. Dated: Auglst 10, 2023 by /s/ Kevin W. Yankowsky Order No. 64460 No. DC-23-01657 HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT OF individually and as next friends of § L.F.B., a Minor § § DALLAS COUNTY, TEXAS VS. § § D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: Integrated Genetics Records Pertaining To: - Type of Records: Any and all medical records from date of birth to present, including, but not limited to, any new patient information, medical records, emergency room records, prescriptions, doctor referrals, radiology reports, pathology reports, insurance records, office notes, office memos, reports, color photographs, audio tapes, video tapes, any and all type of correspondence, and anything else reduced to writing in the possession, custody or control of the said witness. Pertaining to [L.F.B.1, DOB — 1. Please state your full name and the name and address of your employer. Answer: 2. Please state your position and title with the facility identified above. Answer: 3. Have you accepted the subpoena duces tecum accompanying these Direct Questions? Answer: 4. D0 you have personal knowledge of the records as outlined in the subpoena duces tecum? Answer: 5. Are the records outlined in the subpoena duces tecum pertaining to the above-named person in your custody or subject to your control, supervision or direction? Answer: 6. Please attach the copies of the records identified in the subpoena duces tecum. Have you complied? If not, why? Answer: Order No. 64460.031 7. Are the copies that you attached true and correct copies of all such records? Answer: 8. Were such records kept in the regular course of business of this facility? Answer: 9. Was it the regular course of business of this facility for an employee or representative of this facility with knowledge of the act, event, condition, opinion, or diagnosis that was recorded to make the record or to transmit information thereof to be included in such record? Answer: 10. Were the entries on these records made by an employee or representative of this facility at, near the time, or reasonably soon alter the time of the occurrence that was recorded? Answer: ll. Was the method of preparation of these records trustworthy? Answer: WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared , known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. SWORN TO AND SUBSCRIBED before me this day of , 20 Notary Public Notary’s printed name My Commission Expires: Order No. 64460.031 DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS THE STATE OF TEXAS To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under Rule 176 of the Texas Rules of Civil Procedure - GREETINGS - You are hereby commanded to subpoena and summon the following witness(es): Custodian(s) of Records for Integrated Genetics 2000 Vivigen Way, Santa Fe, NM 87505 of my designation for to be and appear before a Notary Public Lexitas (Phone: 713-365-0777) 13101 Northwest Freeway, Suite 330, Houston TX 77040 or its designated agent on the forthwith day of: INSTANTER at the offlce of the Witness, or any other agreed upon place, and there remain from day to day and time to time until discharged according to law. Said above-named Witness is further commanded there, under oath, to make answers of certain written questions to be propounded to the witness and to bring and produce for inspection and photocopying Any and all medical records from date 0f birth t0 present, including, but not limited t0, any new patient information, medical records, emergency room records, prescriptions, doctor referrals, radiology reports, pathology reports, insurance records, office notes, office memos, reports, color photographs, audio tapes, video tapes, any and all type of correspondence, and anything else reduced to writing in the possession, custody or control of the said witness. Pertaining to [L.F.B.], DOB: — and any other such record in the possession, custody or control of the said witness, and every such record to which the witness may have access, pertaining to _ at any and all times whatsoever, then and there to give evidence at the instance of the Defendant, D'Andra Bignham MD, Collom & Carney Clinic Association, represented by Kevin W. Yankowsky, Norton Rose Fulbright US LLP, Phone Number: 713-651-5151, Address: 1301 McKinney Street, Suite 5100, Houston, TX 77010-3095, Attorney of Record, in that Certain Cause No. DC-23-01657 pending on the docket of the District Court of the 134th Judicial District of Dallas County, Texas. This Subpoena is issued under and by virtue of Rule 200 and Notice of Deposition Upon Written Questions on file with the above- named court, styled HUNTER BRIAN and SHELBY SCOTT, individually and as next friends of L.F.B., a Minor vs. D'ANDRA D. BINGHAM, M.D.; COLLOM & CARNEY CLINIC ASSOCIATION; CHRISTUS HEALTH AMC-LA-TEX d/b/a CHRISTUS ST. MICHAEL HEALTH SYSTEM; CHRISTUS HEALTH; SUSAN ELIZABETH KEENEY, M.D.; and PEDIATRIX MEDICAL SERVICES, INC. d/b/a PEDIATRIX MEDICAL GROUP OF TEXAS. WITNESS MY HAND, this 10th day of August, 2023. STEPHANIE L. HAHT efli‘l’zfi ff "gammy Public. Ema of Tam Comm. Expires 02-24mm 53" WI... ‘55.”? ,.-fl§ 60 fluff...» Notary ID 125593433 NOTHHIY PUBLXC 176.8 Enforcement of Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by fine or confinement, or both. OFFICER'S RETURN Came to hand this day of , 20 , and executed this the day of , 20 , in the following manner: By delivering to the witness ,Via [ ] Certified Mail, Return Receipt Requested [ ] Federal Express [ ] Fax [ ]Hand Service [ ] Email [ ] Upload, a true copy hereof. Returned this day of , 20 PROCESS SERVER Order No. 64460.031 No. DC-23—01657 HUNTER BRIAN and SHELBY SCOTT, § IN THE DISTRICT COURT OF individually and as next friends of § L.F.B., a Minor § § DALLAS COUNTY, TEXAS vs. § § D'ANDRA D. BINGHAM, M.D.; et a]. § 134TH JUDICIAL DISTRICT COPY ORDER FORM AND WAIVER OF NOTICE Our cient, Kevn W. Yankowsky, Esq., of Norton Rose Fulbright US LLP, has commissioned Lexitas to obtain documents or things from the following custodian(s) for use in the above-referenced case. IF COPIES ARE DESIRED, please indicate below by marking "Y" OR "N" next to the selected location(s). 31 Integrated Genetics (Medical Records) Fee, per part: $115.00 How would you like your records prepared? { }HaId Copy { }Online download via an e-mailed link Would you like copies of Affidavit/Declaration of No Records? { }Yes { } No Would you like copies of radiology films/CD3 (if available)? { }Yes { } No If you would prefer that we bill the insurance carrier directly, please attach the necessary billing information. I agree that I and my firm will be responsible for payment of the records ordered via this waiver. I acknowledge that invoices are due and payable within 30 days of receipt and that actions for collection of services are performable and payable in Harris County, Texas. _ I DO AGREE TO WAIVE THE NOTICE PERIOD. _ I D0 NOT AGREE TO WAIVE THE NOTICE PERIOD. Dated: Signed Please return to: Lexitas 13101 Northwest Freeway, Suite 330 Comact and Firm Houston, TX 77040 Ph: 713-365-0777 // Fax: 713-365-0808 Email: danyelle.j ackson@lexitaslegal.com DeliVel'y Address Email Address PLEASE RETURN WITHIN 20 DAYS 0F THE ISSUANCE 0F THIS WAIVER. ANY CANCELLATION 0F THE ABOVE MUST BE IN WRITING. IF THE RECORDS HAVE ALREADY BEEN COPIED AND FEES INCURRED, THEN BILLING MLL BE PRORATED ACCORDINGLY. Order No. 64460 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Envelope ID: 78409608 Filing Code Description: Discovery Filing Description: NOTICE OF INTENT Status as of 8/10/2023 2:46 PM CST Associated Case Party: HUNTER BRIAN Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 8/10/2023 2:38:29 PM SENT LES WEISBROD lweisbrod@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT Lori Slywka lorislywka@steedlawfirm.com 8/10/2023 2:38:29 PM SENT C. Holloway Yvetteholloway@steedlawfirm.com 8/10/2023 2:38:29 PM SENT Kathy Dorsey kathydorsey@steedlawfirm.com 8/10/2023 2:38:29 PM SENT Associated Case Party: CHRISTUS HEALTH Name BarNumber Email TimestampSubmitted Status Carlos Mattioli cmattioli@smfadlaw.com 8/10/2023 2:38:29 PM SENT Sherry EKelly skelly@smfadlaw.com 8/10/2023 2:38:29 PM SENT Elizabeth D. (Lisa)Alvarado lalvarado@smfadlaw.com 8/10/2023 2:38:29 PM SENT Debra Boyd dboyd@smfadlaw.com 8/10/2023 2:38:29 PM SENT Associated Case Party: COLLOM & CARNEY CLINIC ASSOCIATION Name BarNumber Email TimestampSubmitted Status Liane Hunt liane.hunt@nortonrosefuIbright.com 8/10/2023 2:38:29 PM SENT Kevin W.Yankowsky kevin.yankowsky@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT Kim Marcum kim.marcum@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT Will Martin will.martin@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT Kristina Williams 24078303 kristina.williams@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT Bertina York bertina.york@nortonrosefuIbright.com 8/10/2023 2:38:29 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Envelope lD: 78409608 Filing Code Description: Discovery Filing Description: NOTICE OF INTENT Status as of 8/10/2023 2:46 PM CST Associated Case Party: COLLOM & CARNEY CLINIC ASSOCIATION Kristina Williams kristina.williams@nortonrosefulbrightcom 8/10/2023 2:38:29 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Evelyn Ivy evelyn.ivy@nortonrosefulbright.com 8/10/2023 2:38:29 PM SENT Bertina B.York bertina.york@nortonrosefu|bright.com 8/10/2023 2:38:29 PM SENT Jon Wayne Stephenson 24041973 jonstephenson@steedlawfirm.com 8/10/2023 2:38:29 PM SENT Matthew Adair 24084471 madair@millerweisbrod.com 8/10/2023 2:38:29 PM SENT Charles Clayton Miller 791266 cmiller@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT Casey Cashion 24103775 caseycashion@steedlawfirm.com 8/10/2023 2:38:29 PM SENT Ashley Fulks afulks@millerweisbrod.com 8/10/2023 2:38:29 PM SENT Carrie Lynn Vine 24128671 cvine@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT Bianca Trejo btrejo@millen~eisbrod.com 8/10/2023 2:38:29 PM SENT Associated Case Party: SUSANELIZABETHKEENEY Name BarNumber Email Timestam pSubmitted Status Betty Goodlow betty.good|ow@cooperscully.com 8/10/2023 2:38:29 PM SENT Associated Case Party: PEDIATRIX MEDICAL SERVICES, INC. Name BarNumber Email TimestampSubmitted Status Cory Sutker cory.sutker@cooperscully.com 8/10/2023 2:38:29 PM SENT