On November 01, 2019 a
Party Statement
was filed
involving a dispute between
Brown, Keyandre J.,
Watkins, Miekisha C.,
and
Flores-Hampton, Lourdes,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
1/22/2020 4:59 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-19-17613
Margaret Thomas
MIEKISHA C. WATKINS AND IN THE DISTRICT COURT
KEYANDRE J. BROWN,
Plaintiffs,
101ST JUDICIAL DISTRICT
V.
LOURDES FLORES—HAMPTON, DALLAS COUNTY, TEXAS
Defendant.
MEDICAL RECORDS AFFIDAVIT OF ACC. & INJ. CHIRO - MESQUITE
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff Keyandre Jrhun Brown files the attached Medical Records Affidavit of
Acc. & Inj. Chiro -
Mesquite in accordance with 902(1 0) of the Texas Rules of Evidence.
Respectfully submitted,
/s/ Griffin Scheumack
Scheumack
Griffin
State Bar No.24097168
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(81 7) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document was
served on all counsel of record and/or pro se parties in accordance with Rules 21 and
21 a of the Texas Rules of Civil Procedure on this 22nd day of January, 2020.
/s/ Griffin Scheumack
Griffin Scheumack
MEDI AL RE RD AFFIDAVIT FA .&INJ. HIR - ME UITE Page 1
, ) Cause No.:
)
Plaintiff, )
) IN THE DISTRICT COURT
vs. )
) DALLAS COUNTY, TEXAS
, )
)
Defendant, )
)
AFFIDAVIT FOR THE AUTHENTICATION OF BUSINESS RECORDS
Before me, the undersigned authority, on this day personally appeared DR. LOU
SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows:
My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making
this affidavit, and personally acquainted with the facts herein stated:
10
I am the custodian of healthcare treatment records for ACCIDENT & INJURY
ll CHIROPRACTIC. Attached hereto are records from 02/04/2019 THRU 03/25/2019,
pertaining to KEYANDRE BROWN, DOB: 04/09/1996, SSN: N/A. These records are
12 kept by ACCIDENT & INJURY CHIROPRACTIC in the regular course of business, and
it was the regular course of business of ACCIDENT & INJURY CHIROPRACTIC for
13 an employee or representative of ACCIDENT & INJURY CHIROPRACTIC, with
knowledge of the act, event, condition, opinion, or diagnoses recorded to
l4
make the records or to transmit information thereof to be included in such
records; and the records were made at or near the time or reasonably after
the time that the service was provided. The records attached hereto are the
15 original or exact duplicates of the original.
l6
l7 Affiant
18 SWORN To AND SUBSCRIBED before me on the \(fi
day of B(K‘ C H C) (Lei , 2019.
/“'3
l9
9%
f
LCM
~
(xi
b
um 3
f
Notary Pu%lic, State of Texas
20 Notary’s printed name and
commission expires:05—13—23
21
22
23
24
25
Document Filed Date
January 22, 2020
Case Filing Date
November 01, 2019
Category
MOTOR VEHICLE ACCIDENT
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FILED DALLAS COUNTY 1/22/2020 4:59 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-19-17613 Margaret Thomas MIEKISHA C. WATKINS AND IN THE DISTRICT COURT KEYANDRE J. BROWN, Plaintiffs, 101ST JUDICIAL DISTRICT V. LOURDES FLORES—HAMPTON, DALLAS COUNTY, TEXAS Defendant. MEDICAL RECORDS AFFIDAVIT OF ACC. & INJ. CHIRO - MESQUITE TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff Keyandre Jrhun Brown files the attached Medical Records Affidavit of Acc. & Inj. Chiro - Mesquite in accordance with 902(1 0) of the Texas Rules of Evidence. Respectfully submitted, /s/ Griffin Scheumack Scheumack Griffin State Bar No.24097168 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (81 7) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document was served on all counsel of record and/or pro se parties in accordance with Rules 21 and 21 a of the Texas Rules of Civil Procedure on this 22nd day of January, 2020. /s/ Griffin Scheumack Griffin Scheumack MEDI AL RE RD AFFIDAVIT FA .&INJ. HIR - ME UITE Page 1 , ) Cause No.: ) Plaintiff, ) ) IN THE DISTRICT COURT vs. ) ) DALLAS COUNTY, TEXAS , ) ) Defendant, ) ) AFFIDAVIT FOR THE AUTHENTICATION OF BUSINESS RECORDS Before me, the undersigned authority, on this day personally appeared DR. LOU SAUCEDO, JR., D.C., who, being by me duly sworn, deposed as follows: My name is DR. LOU SAUCEDO, JR., D.C., I am of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: 10 I am the custodian of healthcare treatment records for ACCIDENT & INJURY ll CHIROPRACTIC. Attached hereto are records from 02/04/2019 THRU 03/25/2019, pertaining to KEYANDRE BROWN, DOB: 04/09/1996, SSN: N/A. These records are 12 kept by ACCIDENT & INJURY CHIROPRACTIC in the regular course of business, and it was the regular course of business of ACCIDENT & INJURY CHIROPRACTIC for 13 an employee or representative of ACCIDENT & INJURY CHIROPRACTIC, with knowledge of the act, event, condition, opinion, or diagnoses recorded to l4 make the records or to transmit information thereof to be included in such records; and the records were made at or near the time or reasonably after the time that the service was provided. The records attached hereto are the 15 original or exact duplicates of the original. l6 l7 Affiant 18 SWORN To AND SUBSCRIBED before me on the \(fi day of B(K‘ C H C) (Lei , 2019. /“'3 l9 9% f LCM ~ (xi b um 3 f Notary Pu%lic, State of Texas 20 Notary’s printed name and commission expires:05—13—23 21 22 23 24 25