Preview
FILED
5/20/2020 10:50 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
N0. DC-20-03592
ABRAM MONTEMAYOR AND
ENRIQUE MONTEMAYOR § IN THE DISTRICT COURT
PLAINTIFF, §
§
§
VS. § DALLAS COUNTY, TEXAS
§
SOE WIN §
DEFENDANT. §
192NI’ JUDICIAL DISTRICT
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE T0 PLAINTIFFS’
REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS
Pursuant t0 TeX R. Civ. P. 194, Defendant serves the following First Supplemental
Response t0 Plaintiffs’ Request for Disclosure and Designation 0f Experts.
f. For any testifying expert:
1. The expert’s name, address, and telephone number;
2. The subj ect matter 0n which the expert Will testify;
3. The general substance 0f the expert’s mental impressions and opinions and
a brief summary 0f the basis for them, or if the expert is not retained by, employed by, 0r
otherwise subject t0 the control of the responding party, documents reflecting such
information;
4. Ifthe expert is retained by, employed by, or otherwise subj ect t0 the control
0f the responding party:
A. A11 documents, tangible things, reports, models, 0r data
compilations that have been provided t0, reviewed by, 0r prepared by or for the
expert in anticipation 0f the expert’s testimony; and
B. The expert’s current resume 0r bibliography.
Response: Defendant hereby designates and reserves the right to call any expert Witness(es)
designated by any other party t0 this case, as well as any experts later designated
by any party to this case on any subject relevant to this litigation on which the
Witness is qualified t0 testify. In the event that any party t0 this cause has
designated any experts but has been 0ris subsequently dismissed for any reason 0r
fails to callany designated expert at the time of trial, Defendant specifically
reserves the right t0 call any such expert previously designated by that party.
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1-
Defendant further reserves the right t0 withdraw 0r de-designate any expert prior
t0 testimony and to positively aver that such previously designated expert Will not
be called as a Witness at trial and t0 redesignate same as a consulting expert Who
will not be called by any party in this cause. Finally, Defendant reserves the right
t0 supplement this response as additional information concerning experts becomes
available.
Defendant further hereby designates as adverse expert witnesses all expert
Witnesses designated by Plaintiffs. Defendant reserves the right t0 rely upon 0r t0
offer, by direct examination or cross—examination, testimony obtained from those
experts and rebuttal experts, if any, designated by Plaintiffs. By this designation,
Defendant does not necessarily agree With, nor vouch for, the credibility 0f any
such Witnesses 0r their opinions, or the reliability, materiality, 0r admissibility of
information and/or tangible things produced by these individuals in general; by this
designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit
certain opinions and/or evidence from these witnesses t0 the extent that it deems it
in its interest t0 d0 s0.
Such persons are expected t0 testify concerning Plaintiffs’ care and treatment. See
Plaintiffs’ Responses t0 Defendant’s Request for Disclosure for additional
information concerning such health-care providers including medical bills and
records relating to Plaintiffs.
First Supplemental Response:
Defendant hereby designates as an expert witness the following individual:
Andrew Goodman, DC
2046 Forest Lane, Ste. 180
Garland, Texas 75042
972.265.8104
Dr. Goodman is chiropractor who has reviewed Abram Montemayor’s medical records
and other case materials provided t0 him and is expected t0 testify regarding the extent of
the injuries sustained by the Plaintiff in the subj ect motor vehicle accident, the appropriate
care and treatment for those injuries, and the fair and reasonable cost 0f that treatment, both
in the past and in the future, if applicable, as set out in the attached report.
Andrew Goodman, DC
2046 Forest Lane, Ste. 180
Garland, Texas 75042
972.265.8104
Dr. Goodman is chiropractor who has reviewed Enrique Montemayor’s medical records
and other case materials provided t0 him and is expected t0 testify regarding the extent 0f
the injuries sustained by the Plaintiff in the subj ect motor vehicle accident, the appropriate
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2-
care and treatment for those injuries, and the fair and reasonable co st of that treatment, both
in the past and in the future, if applicable, as set out in the attached report.
Respectfully submitted,
¢f/fl
Chad Kimble, Bar N0. 24007483
State
Kyle Smith, State Bar N0. 24102512
D. Brent Beasley, State Bar N0. 24082669
LAW OFFICE 0F CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
The undersigned celtifies that 0n the 20th day of May, 2020, a true copy of the foregoing
has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure.
Kyle Smith
DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3-
ANDREW GOODMAN, D.C. 12001 N. CENTRAL EXPRESSWAY
DOCTOR 0F CHIROPRACTIC SUITE 800
DALLAS, TX 75243
(214) 750-61 10
FAX -
(214) 750—5825
May 15, 2020
Mr. Chad Kimble
Law Office of Chad Kimble
1204 South White Chapel Blvd.
Southlake, TX 76092
RE: Abram Montemayer
CLAIM #: 0550252365
DATE OF INJURY: 06/18/19
CASE #: 21118418
Dear Mr. Kimble:
| have had the opportunity to review medical records on Mr. Abram Montemayer.
My name is Andrew Goodman, DC. Cum Laude from Parker College of Chiropractic in 2008.
| graduated |
have had chiropractic practices and Dallas, TX seeing and treating many patients who were
in Plano, TX
subject to musculoskeletal injuries of the spine and the extremities. was also the Director of Rehabilitation for
|
Alpha Physical Medicine, the rehabilitation center for Alpha Orthopedics, seeing and treating hundreds of post-
operative and non-operative patients, many of whom were injured due to traumatic incidences of falls, motor
vehicle accidents, and fractures. have had direct patient experience with thousands of patients during my
|
time as a Doctor of Chiropractic. maintain an active license and work as an independent contractor for an
|
occupational medicine performing pre-employment physicals, Department of Transportation physicals,
clinic
and workers’ compensation injuries and independent medical evaluations to determine MMI and assign
impairment ratings. am a Nationally Registered Certified Medical Examiner for the Department of
|
Transportation and a certified Designated Doctor with the Texas Department of Insurance Division of Workers’
Compensation. have several years of experience setting fee schedules, billing third-party reimbursement and
|
discussing third-party reimbursement with patients.
OVERVIEW:
On June 18, 2019, the patient was involved in a motor vehicle accident.
On June 20, 2019, the patient Injury Care Auto & Work Chiropractic for an initial examination
presented to
complaining of neck pain and numbness and tingling of the upper extremities, mid back pain, low
stiffness,
back pain with numbness and tingling of the lower extremities, left hand and left wrist severe pain, left knee
pain and discomfort. Cervical spine range of motion is restricted in flexion, extension and rotation bilaterally.
Lumbar spine range of motion is decreased in flexion, extension, rotation and side bending. Left wrist range of
motion is decreased.
Compression negative in the cervical spine, Adson's maneuver is negative in the cervical spine, shoulder
test is
depression test is negative in the cervical spine, Soto-Hall test is negative in the cervical spine. Lasegue straight
leg test is negative in the lumbar spine. Patrick-Faber test is negative in the lumbar spine. Kemp’s test is
negative in the lumbar spine. Yeoman’s test is negative in the lumbar spine. Ely’s and hyperextension test of
the lumbar spine are negative. Phalen’s test is negative in the left wrist. Tinel’s test is negative in the left wrist.
Finkelstein’s is negative in the left wrist. Treatment in this date consisted of cold therapy, traction, EMS, massage
and therapeutic activities.
Abram Montemayer
May 15, 2020
CASE #: 21118418
Page 2 of 7
On June 21, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment. Treatment
consisted of cold therapy, traction, EMS, massage and therapeutic activities.
On June 26, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment consisting of
cold therapy, traction, EMS, massage and therapeutic activities.
On June 28, 2019, the patient had x-rays of the left knee with the following impression, no acute radiographic
abnormality. Patient had x-rays of the lumbar spine with the following impression, no radiographic abnormality
of the lumbar spine. Patient had thoracic spine x-rays with the following impressions, no radiographic
abnormality of the thoracic spine.
X-rays of the lumbar spine for the patient revealed the following impressions, loss of lordotic curve, possible mild
retrolisthesis at L5-S1. No evidence of fracture or osseous destructive lesion. Patient had x-rays of the left hand
with the following impression: A fifth metacarpal base fracture. Patient had x-rays of the cervical spine with
the following impression: No acute finding demonstrated. Thoracic spine x-rays for the patient revealed the
following impression: Thoracic spine is within normal limits. Right knee x-rays revealed the following impression
for the patient: Right knee is within normal limits.
On June 28, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, massage and therapeutic exercise.
On July 1, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of
cold therapy, mechanical traction, EMS, therapeutic activities and manipulation.
On July 3, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of
cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation.
On July 5, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of
cold therapy, traction, EMS, massage, and therapeutic activities.
On July 8, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of
cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation.
On July 11, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, massage, and therapeutic activities.
On July 15, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, manual traction, therapeutic activities and manipulation.
On July 17, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation.
On July 18, 2019, the patient presented to DFW MRI for an MRI of the lumbar spine with the following impression,
no acute fracture evidence, stress injury or spondylolisthesis, straightening of normal lumbar lordosis, which
could be positional or due to lumbar strain, these clinically correlate.
On July 23, 2019, the patient presented to DFW MRI for an x-ray of his left hand with the following impressions,
minimally displaced healing fracture involving the base of the fifth metacarpal.
On July 23, 2019, the patient presented for left wrist x-rays with the following impressions, no acute osseous
abnormality.
Abram Montemayer
May 15, 2020
CASE #: 21 1 18418
Page 3 of 7
On July 24, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation.
On July 25, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction and EMS.
On July 29, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation.
On July 31, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted
of heat therapy, mechanical traction, EMS, therapeutic activities, manual traction and manipulation.
On August 2019, the patient presented to Injury Care Auto
2, & Work Chiropractic for treatment, which
consisted of cold therapy, traction, EMS, and ultrasound.
On August 5, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, manipulation, and extremity
manipulation.
On August 7, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation.
On August 12, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of manual traction, manipulation of the spine and extremity manipulation.
On August 19, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of manual traction, manipulation of the spine and manipulation of the extremities.
On August 26, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of manual traction, manipulation of the spine and manipulation of the extremities.
On September 4, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which
consisted of manual traction, manipulation of the spine and manipulation of the extremities.
On September 23, 2019, the patient presented to Injury Care Auto & Work Chiropractic for final evaluation and
on this date, the patient was released from care.
RESPONSEIOPINION:
The following opinion is based upon my education, treatment experience and commonly accepted
chiropractic treatment guidelines. have had direct patient experience with thousands of patients during my
|
time as a Doctor of Chiropractic. maintain an active license and work as an independent contractor for an
|
occupational medicine clinic where perform pre-employment physicals, Department of Transportation
|
physicals, and Workers' Compensation injuries. am a Nationally Registered Certified Medical Examiner for the
|
Department of Transportation and a certified Designated Doctor with the Texas Department of Insurance
Division of Workers' Compensation. have several years of experience setting fee schedules, billing third-party
|
reimbursement and discussing third-party reimbursement with patients.
The patient was involved in a motor vehicle accident on June 18, 2019. On June 20, 2019, the patient
presented to Injury Care Chiropractic for initial evaluation. The patient’s initial evaluation is suggestive of signs
and symptoms that are consistent with cervical, thoracic and lumbar strains and sprains, status post motor
vehicle collision. This type of treatment qualifies for an initial trial of care of 6 visits over the course of 2 weeks at
which point a re-examination should be performed to determine a functional progress is being achieved. The
Abram Montemayer
May 15, 2020
CASE #: 21118418
Page 4 of 7
sixth visit took place on July 1, 2019, however, at no point during the patient’s plan of care was a re-
examination ever performed based on the documentation provided. Therefore any and/or chiropractic
services and treatments should have stopped after the sixth visit on July 1, 2019.
The following charges are not reasonable, based on usual and customary rates with regard to similar changes
provided in that geographic region. CPT code 97010, hot/cold pack was billed $15, this should not have been
billed, as this type of treatment is not indicated to be clinically efficacious. CPT code 97012, mechanical
traction was billed $65, should not have been billed more than $32. CPT code 97032, electrical muscle
stimulation was billed $65, should not have been billed more than $31. CPT code 97110, therapeutic exercise
billed $80 per unit, should not have been billed more than $64 per unit. CPT code 97140, manual therapy was
billed $80 per unit, should not have been billed more than $59 per unit. CPT code 98940, manipulation in one or
two areas was billed $135, should not have been billed more than $59.
CPT code 97124, massage was billed $75, should not have been billed more than $61. CPT code 99203 was
billed $260, this is improper use of evaluation and management coding, this was not billed on the first visit date,
but on the third visit date, it should have been billed on the first visit date and should not have been billed more
than $220. CPT code 99213 was billed $110 this is improper use of evaluation and management coding as
there is no evidence to support that an examination of this level was performed on June 26, 2019. CPT code
97035, ultrasound was billed $65, should not have been billed more than $30. CPT code 98943, extremity
manipulation was billed $80, should not have been billed more than $57. CPT code 99214, re-examination was
billed $165, this is improper use of evaluation and management coding as there is no documentation to
support that an exam of this level was performed on the following dates of August 7, 2019 and August 12, 2019.
Patient had a lumbar MRI performed. Based on the records provided, this was a referral that was made on the
initial evaluation at Injury Care Chiropractic. This referral for an MRI is not necessary for this patient. The patient
did not have any orthopedic findings such as a positive Lasegue straight leg raise and 0-30 degrees with
radicular pain going from the low back down the lower extremity. There is no documentation of a loss of reflex
from one side to the other nor is there a documentation of any muscle weakness and this type of
documentation would be needed to necessitate a referral for an MRI to evaluate for any type of soft tissue
injury occurring in the lumbar spine because none of that documented anywhere in the patient’s chart. The
lumbar MRI is not necessary for this patient. The lumbar MRI CPT code 72148 was billed $3012, this should not
have been billed more than $463.
To calculate fees, I utilized an average of what providers in that geographic region charge.
The following is an opinion on future treatment and costs based on the records provided. In my opinion, there is
no need for any future treatment and there should be no future treatment costs for this patient based on the
injuries sustained in the motor vehicle accident;
Thank you for the opportunity to review the medical records on Mr. Abram Montemayer.
Dictated, reviewed, opinion verified, and attested to by my original signature.
Sincerely,
5%;
Andrew Goodman, D.C.
Doctor of Chiropractic
11008
AG/sm/ANS/lea
Abram Montemayer
May 15, 2020
CASE #: 21118418
Page 5 of 7
The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the
basis of the medical records provided, with the assumption that the material is true and correct. If more
information becomes available at a later date, an additional service/report/reconsideration may be
requested.
Abram Montemayer
May 15, 2020
CASE #: 21118418
Page 6 of 7
SUMMARY OF RECORDS
• Texas Peace Officer’s Crash Report, 06/18/19
• Injury Care Auto & Work Chiropractic, Margarita Pena-Obando, D.C., 06/20/19, 06/21/19, 06/26/19,
06/28/19, 07/01/19, 07/03/19, 07/05/19, 07/08/19, 07/11/19, 07/15/19, 07/17/19, 07/24/19, 07/25/19,
07/29/19, 07/31/19, 08/02/19, 08/05/19, 08/07/19, 08/12/19, 08/19/19, 08/26/19, 09/04/19, 09/23/19,
10/02/19
• DFW Open MRI, Michael Lloyd, M.D./James Schroeder, M.D./Mumtaz Syed, M.D./Joel Carp,
M.D./Solomon Bierman, M.D., 06/28/19, 07/18/19, 07/23/19, 09/09/19
• O’Reilly Auto Parts, 07/01/19, 07/08/19
• AM/PM Medical Centers, Philip Rodriguez, F.N.P., D.C., 07/11/19, 08/02/19
• Comprehensive Spine Center, Scott Farley, D.O./Phat Truong, P.A.-C., 07/16/19, 08/06/19, 08/13/19,
09/20/19
• Plaintiff’s Responses to Defendant’s Request for Disclosure, 04/30/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, AM/PM Medical Centers,
03/06/20
• Affidavit of Medical Records, AM/PM Medical Centers, 03/06/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, ASP Cares Pharmacy,
03/05/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, Comprehensive Spine
Center of Dallas, 03/09/20
• Affidavit of Medical Records, Comprehensive Spine Center of Dallas, 03/09/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, DFW Open MRI, 03/06/20
• Affidavit of Medical Records, DFW Open MRI, 03/06/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, Injury Care Chiropractic,
03/04/20
• Affidavit of Medical Records, Injury Care Chiropractic, 03/04/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, Metroplex DME, 03/09/20
• Affidavit of Medical Records, Metroplex DME, 03/09/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, PeopleFirst Pharmacy,
03/10/20
• Affidavit Establishing Necessity and Reasonableness of Services and Charges, Singleton Associates, P.A.,
03/16/20
• Plaintiff Abram Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20
• Plaintiff Enrique Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20
• Plaintiff Abram Montemayor’s Objections and Responses to Defendant’s Request for Production,
04/30/20
• Plaintiff Enrique Montemayor’s Objections and Responses to Defendant’s Request for Production,
04/30/20
• Color Photographs, 10 pages
• Itemized Statement, AM/PM Medical Centers, Date of Service, 07/11/19-08/02/19
• Itemized Statement, Patient Profile Report, ASP Cares, Date of Service, 07/16/19-07/17/19
• Itemized Statement, Comprehensive Spine Center, Dates of Service, 07/16/19-09/20/19
• Health Insurance Claim Form, Comprehensive Spine Center, Phat Truong, N.P.-C., 07/16/19, 08/06/19,
08/13/19, 09/20/19
• Itemized Statement, DFW Open MRI, Dates of Service, 06/28/19-09/09/19
• Health Insurance Claim Form, DFW Open MRI, 06/28/19, 07/18/19, 07/23/19, 09/09/19
• Itemized Statement, Injury Care Chiropractic, Dates of Service, 06/20/19-09/23/19
• Payment Inquiry, O’Reilly Auto Parts, Dates of Service, 12/06/18-09/26/19
• Itemized Statement, Metroplex DME, Date of Service, 07/16/19
• Health Insurance Claim Form, Metroplex DME, Scott Farley, D.O., 07/16/19
• Itemized Statement, PeopleFirst Pharmacy, Date of Service, 07/15/19
• Itemized Statement, Singleton Associates, Dates of Service, 06/28/19-09/09/19
Abram Montemayer
May 15, 2020
CASE #: 21118418
Page 7 of 7
• Itemized Statement, AM/PM Medical Centers, Date of Service, 07/11/19
• Itemized Statement, DFW Open MRI, Date of Service, 06/28/19-07/18/19
• Itemized Statement, Injury Care Chiropractic, Dates of Service, 06/20/19-10/02/19
• Itemized Statement, Singleton Associates, Dates of Service, 06/28/19-07/18/19
ANDREW GOODMAN, D.C. 12001 N. CENTRAL EXPRESSWAY
DOCTOR OF CHIROPRACTIC SUITE 800
DALLAS, TX 75243
(214) 750—61 10
FAX —
(21 4) 750-5825
May 15, 2020
Mr. Chad Kimble
Low Office of Chad Kimble, PC
1204 S. Whi’re Chapel Blvd.
Sou’rhloke, TX 76092
RE: Enrique Mon’remoyor
CLAIM#: 0550252365
DATE OF INJURY: 06/18/19
CASE#: 21 18428
1
Dear Mr. Kimble:
| hove had The opportunity ’ro review medical records on Mr. Enrique Mon’remoyor.
My name is Andrew Goodman, DC. | graduated Cum Loude from Parker College of Chiroproc’ric in 2008. |
hove had chiropractic practices 0nd Dallas, TX seeing 0nd Treating many po’rien’rs who were
in Plano, TX
subjec’r ’ro musculoskele’rol injuries of ’rhe spine 0nd The ex’rremi’ries. was also ’rhe Director of Rehabilitation for
|
Alpha Physical Medicine, ’rhe rehabilitation cen’rer for Alpha Orthopedics, seeing 0nd Treo’ring hundreds of pos’r-
operative 0nd non-opero’rive po’rien’rs, many of whom were injured due ’ro Traumatic incidences of falls, mo’ror
vehicle occiden’rs, 0nd froc’rures. hove had direct po’rien’r experience wi’rh Thousands of po’rien’rs during my
|
’rime as o Doc’ror of Chiropractic. moin’roin on oc’rive license 0nd work Gs on independent confroc’ror for on
|
occupo’rionol medicine clinic performing pre-employmen’r physicals, Depor’rmen’r of Tronspor’ro’rion physicals,
0nd workers’ compensation injuries 0nd independent medical evaluations ’ro de’rermine MMI 0nd assign
impairment ro’rings. om c1 Nationally Registered Certified Medical Examiner for ’rhe Deportmen’r of
|
Transportation cmd c1 certified Designated Doc’ror wi’rh ’rhe Texas Department of Insurance Division of Workers’
Compenso’rion. | hove several years of experience se’r’ring fee schedules, billing Third-por’ry reimbursement 0nd
discussing Third-por’ry reimbursement wi’rh po’rien’rs.
OVERVIEW
On June presented To Injury Core Au’ro & Work Chiropractic for on ini’riol visi’r. The po’rien’r
20, 2019, The pofien’r
complained neck pain 0nd stiffness, numbness 0nd Tingling of The upper extremities, mid back pain, low
of
back pain wi’rh numbness 0nd Tingling in The lower extremities, Ief’r elbow pain, righ’r wris’r pain, 0nd bilo’rerol
knee pain. Cervical range of mo’rion wos restricted in flexion, extension, 0nd ro’ro’rion bilo’rerolly 0nd Io’rerol
flexion. Compression ’res’r wos negative, Adson’s maneuver wos negative, shoulder depression Tes’r wos
nego’rive, 0nd So’ro—Holl Test was negative. The lumbar spine had decreased rcmge of mo’rion in flexion,
extension, ro’rofion, 0nd Io’rerol flexion. Loségue’s straight leg raise ’resT wos negative. Po’rrick/Fober ’resT wos
nego’rive. Kemp’s Test wos negative. Yeomon’s Tes’r was negative. Ely’s hyper—exfension of The lumbar spine
was negative. Lef’r elbow range of mo’rion was normal. Cozen’s ’res’r wos negative. Mill’s ’res’r wos negative.
Righ’r wris’r range of mo’rion was wi’rhin normal wos negative. Tinel’s ’res’r wos negative.
limi’rs. Pholen’s ’res’r
Finkelstein’s wos negative.
’res’r knee examination range of mo’rion wos wi’rhin normal limi’rs. Volgus
Bilo’rerol
0nd vorus s’rress ’res’rs negative, Drawer ’res’r negative, McMurroy’s ’res’r were negative. Reflexes were normal
cmd normal sensation ’ro pinprick. Treatment on This date consisted of cold Therapy, mechanical Troc’rion, EMS
(electrical muscle stimulation), massage, 0nd Therapeutic oc’rivi’ries.
On June 21, 2019, The potien’r presented ’ro Injury Core Chiroproc’ric for Treatment which consis’red of cold
’rheropy, ’rroc’rion, EMS, massage, 0nd Therapeutic oc’rivi’ries.
Enrique Montemayor
May 15, 2020
CASE#: 21118428
Page 2 of 5
On June 24, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, massage, and therapeutic activities.
On June 26, 2019, the patient presented to Injury Care Auto and Work Chiropractic for treatment which
consisted of cold therapy, traction, EMS, massage, and therapeutic activities.
On June 28, 2019, the patient presented to DFW MRI for lumbar spine x-rays with the following impressions: No
radiographic abnormality of the lumbar spine. The patient also presented for left elbow x-rays with the
following impression: No acute radiographic abnormality. The patient had right hand x-rays with the following
impression: No acute radiographic abnormality. The patient had cervical spine x-rays with the following
impression: No acute radiographic abnormality of the cervical spine. The patient had mid-back x-rays with the
following impression: No radiographic abnormality of the thoracic spine. The patient had right knee x-rays with
the following impression: No acute radiographic abnormality. The patient had left knee x-rays with following
impression: No acute radiographic abnormality.
On June 28, 2019, the presented to Injury Care Chiropractic for treatment which consisted of cold therapy,
traction, EMS, massage, and therapeutic activities.
On July 1, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, therapeutic activities, manual traction, and manipulation.
On July 3, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, therapeutic activities, manual traction, and manipulation.
On July 5, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, and EMS.
On July 8, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, manual traction, and manipulation.
On July 10, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, therapeutic activities, manual traction, and manipulation of the spine and manipulation
of the left knee.
On July 11, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, massage, and therapeutic activities.
On July 17, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, therapeutic activities, manual traction, and manipulation.
On July 18, 2019, the patient presented to DFW MRI for an MRI of the left knee with the following impressions:
No MRI abnormality of the left knee.
On July 24, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, traction, EMS, therapeutic activities, manual traction, manipulation, and manipulation of the left knee.
On July 31, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, mechanical traction, EMS, therapeutic activities, ultrasound, manual traction, and manipulation.
On August 2, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat
therapy, mechanical traction, EMS, therapeutic activity, and ultrasound.
Enrique Montemayor
May 15, 2020
CASE#: 21118428
Page 3 of 5
On August 5, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold
therapy, EMS, therapeutic activities, manual traction, and manipulation.
On August 7, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual
traction, manipulation of the spine and manipulation of the left knee.
On August 15, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat
therapy, EMS, and ultrasound.
On August 23, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat
therapy and EMS.
On August 26, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual
traction, spine manipulation, and left knee manipulation.
On September 4, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of
manual traction and manipulation.
On October 2, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual
traction and on this date the patient had a final examination and was released from care.
DISCUSSION/OPINION
The following opinion was based upon my education, treatment experience, and commonly accepted
chiropractic treatment guidelines. I have had direct patient experience with thousands of patients during my
time as a Doctor of Chiropractic. I maintain an active license and work as an independent contractor for an
Occupational Medicine Clinic, where I perform pre-employment physicals, Department of Transportation
physicals, and Workers' Compensation injuries. I am a Nationally Registered Certified Medical Examiner for the
Department of Transportation and a certified Designated Doctor with the Texas Department of Insurance
Division of Workers' Compensation. I have several years of experience setting fee schedules, billing third-party
reimbursement and discussing third-party reimbursement with patients.
With regard to the necessity of treatment at Injury Care Chiropractic, the patient was involved in a motor
vehicle accident on June 18, 2019. On June 20, 2019, the patient presented to Injury Care Chiropractic for
treatment with an initial examination suggestive of cervical, thoracic, and lumbar strains and sprains as well as
extremity contusions of the knees and right wrist and left elbow. This type of treatment, as it relates to the spine,
qualifies for a trial of care consisting of six visits over the course of two weeks after which a re-examination
should be performed to establish if functional progress is being achieved. The initial examination and visit was
on June 20, 2019. The sixth visit took place on July 1, 2019. However, there was not a re-examination performed
on that sixth visit on July 1, 2019, and there was not a re-examination performed at any point during the
patient’s plan of care. Therefore, because there was no re-examination performed on the sixth visit on July 1,
2019, or any other time during the patient’s plan of care, all chiropractic care should have ceased after the
visit on July 1, 2019.
Following is an opinion on the reasonableness of charges and pricing from Injury Care Chiropractic. To
calculate fees, I utilized an average of what providers in that geographic region charge. The following charges
are not reasonable with regard to usual and customary rates for similar services performed in a similar
geographic region:
CPT Code 97010, hot and cold pack was billed $15, this should not have been billed as this type of
treatment is not indicated to be clinically efficacious.
CPT Code 97012, mechanical traction was billed $65, this should not have been billed more than $32.
Enrique Montemayor
May 15, 2020
CASE#: 21118428
Page 4 of 5
CPT Code 97032, electrical muscle stimulation was billed $65, this should not have been billed more
than $31.
CPT Code 97124, mechanical massage was billed $75, this should not have been billed more than $61.
CPT Code 97112, therapeutic activities was billed $80, this should not have been billed more than $64.
CPT Code 99203, initial examination was billed $260. This is an improper use of evaluation and
management coding. This was billed on June 24, 2019, which was actually the third visit which should
have been billed on the first visit and should not have been billed more than $220.
CPT Code 99213, established patient re-examination was billed $110, this should not have been billed as
there was no evidence to support that an examination of this level took place on the date of June 26,
2019.
CPT Code 98940, manipulation of one to two regions of the spine was billed $135, this should not have
billed more than $59.
CPT Code 97140, manual therapy was billed $80, this should not have been billed more than $58.
CPT Code 98943, extra-spinal manipulation was billed $80, this should not have been billed more than
$57.
CPT Code 99214, established patient re-examination was billed $165. This is an improper use of
evaluation and management coding as there was no evidence to support that a re-examination was
performed on this date at this level on August 7, 2019.
With regard to the necessity of the referral of the MRIs at DFW MRI, on July 18, 2019, the patient presented for an
MRI of the left knee. This referral for a left knee MRI was not necessary for this patient. Based on the records
provided, the patient never had any soft tissue injuries that would warrant additional imaging beyond an x-ray.
There was no documentation of swelling, no documentation of orthopedic findings that would be indicative of
soft tissue injury such as a positive McMurray’s test, positive Lachman’s, or positive Drawer tests that would
indicate that some type of ligamentous or soft tissue injury has occurred and qualifies for additional imaging.
None of this was documented anywhere in the patient’s records. Therefore, the left knee MRI was not
necessary for this patient.
The following is an opinion on the reasonableness of the charges for the MRI at DFW MRI. The following charge
is unreasonable as it relates to similar charges in that geographic region:
CPT Code 73721, left knee MRI was billed $2,620, this should not have been billed more than $475.
The following opinion is regarding future treatment and costs based on the injuries sustained by the patient from
this motor vehicle accident. My opinion is that there is no need for any future treatment and no future costs as
it relates to injuries sustained by the patient from this motor vehicle accident.
Thank you for the opportunity to review the medical records on Mr. Enrique Montemayor.
Dictated, reviewed, opinion verified, and attested to by my original signature.
Sincerely,
6%4/
Andrew Goodman, D.C.
Doctor of Chiropractic
11008
AG/kf/ANS/str
The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the
basis of the medical records provided, with the assumption that the material is true and correct. If more
information becomes available at a later date, an additional service/report/reconsideration may be
requested.
Enrique Montemayor
May 15, 2020
CASE#: 21118428
Page 5 of 5
SUMMARY OF RECORDS
Texas Peace Officer’s Crash Report, 06/18/19
Injury Care Auto & Work Chiropractic, Margarita Pena Obando, D.C., 06/18/19, 06/20/19, 06/21/19,
06/24/19, 06/26/19, 06/28/19, 07/01/19, 07/03/19, 07/05/19, 07/08/19, 07/10/19, 07/11/19, 07/17/19,
07/24/19, 07/31/19, 08/02/19, 08/05/19, 08/07/19, 08/15/19, 08/23/19, 08/26/19, 09/04/19, 10/02/19
DFW MRI, Michael Lloyd, M.D., 06/28/19, 07/18/19
AM PM Medical Centers, Phillip Rodriguez, F.N.P. D.C., 07/11/19
Plaintiff’s Responses to Defendant’s Request for Disclosure, 04/30/20
Affidavit Establishing Necessity and Reasonableness of Services and Charges, AM/PM Medical Centers,
03/06/20
Affidavit for Medical Records, AM/PM Medical Centers, 03/06/20
Affidavit Establishing Necessity and Reasonableness of Services and Charges, DFW Open MRI, 03/06/20
Affidavit for Medical Records, DFW Open MRI, 03/06/20
Affidavit Establishing Necessity and Reasonableness of Services and Charges, Injury Care Chiropractic,
03/04/20
Affidavit for Medical Records, Injury Car Chiropractic, 03/04/20
Affidavit Establishing Necessity and Reasonableness of Services and Charges, Singleton Associates, P.A.,
03/10/20
California Jurat, 03/16/20
Plaintiff Abram Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20
Plaintiff Enrique Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20
Plaintiff Abram Montemayor’s Objections and Responses to Defendant’s Request for Production,
04/30/20
Plaintiff Enrique Montemayor’s Objections and Responses to Defendant’s Request for Production,
04/30/20
Color Vehicle Photographs, 9 pages
Itemized Statement, AM PM Medical Centers, Statement Date, 08/06/19; Dates of Service, 07/11/19
Itemized Statement, DFW Open MRI, LP, Statement Date, 03/05/20; Dates of Service, 06/28/19 – 07/18/19
Health Insurance Claim Form, DFW MRI Garland, 06/28/19, 07/18/19
Itemized Statement, Injury Care Chiropractic, Statement Date, 10/11/19; Dates of Service, 06/20/19 –
10/02/19
Itemized Statement, PeopleFirst Pharmacy, Statement Date, 03/10/20; Dates of Service, 07/15/19
Itemized Statement, Singleton Associates, PA, Statement Date, 03/16/20; Dates of Service, 06/28/19 –
07/18/19
Andrew Goodman, D.C.
Dallas, TX 75248
PROFESSIONAL SUMMARY
Extensive experience building patient relationships and delivering exceptional medical care as part of a collaborative
medical team
o Promoted health and wellness as a licensed chiropractor, addressing a wide range of medical problems.
o Developed multiple partnerships with doctors and specialists to address patient total wellbeing.
o High academic success and strong marks and reviews earned on all clinical rotations.
o Thrive in fast paced medical environments. Enjoy problem solving to answer tough problems.
CHIROPRACTIC EXPERIENCE
Chiropractor/Health Care Provider, Occumed Plus, Dallas, September 2017 — Present
TX
Performed pre-employment assessments and ongoing medical examinations for the Department of Transportation.
Evaluated, diagnosed, and documented acute care management for work related injuries. Communicated work
restrictions, improvements, and assigned impairment ratings.
Designated Doctor/lndependent Peer Reviewer, Exam Works, March 2018 — Present
Preview
FILED 5/20/2020 10:50 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAROLYN SELLERS DEPUTY N0. DC-20-03592 ABRAM MONTEMAYOR AND ENRIQUE MONTEMAYOR § IN THE DISTRICT COURT PLAINTIFF, § § § VS. § DALLAS COUNTY, TEXAS § SOE WIN § DEFENDANT. § 192NI’ JUDICIAL DISTRICT DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE T0 PLAINTIFFS’ REQUEST FOR DISCLOSURE AND DESIGNATION 0F EXPERTS Pursuant t0 TeX R. Civ. P. 194, Defendant serves the following First Supplemental Response t0 Plaintiffs’ Request for Disclosure and Designation 0f Experts. f. For any testifying expert: 1. The expert’s name, address, and telephone number; 2. The subj ect matter 0n which the expert Will testify; 3. The general substance 0f the expert’s mental impressions and opinions and a brief summary 0f the basis for them, or if the expert is not retained by, employed by, 0r otherwise subject t0 the control of the responding party, documents reflecting such information; 4. Ifthe expert is retained by, employed by, or otherwise subj ect t0 the control 0f the responding party: A. A11 documents, tangible things, reports, models, 0r data compilations that have been provided t0, reviewed by, 0r prepared by or for the expert in anticipation 0f the expert’s testimony; and B. The expert’s current resume 0r bibliography. Response: Defendant hereby designates and reserves the right to call any expert Witness(es) designated by any other party t0 this case, as well as any experts later designated by any party to this case on any subject relevant to this litigation on which the Witness is qualified t0 testify. In the event that any party t0 this cause has designated any experts but has been 0ris subsequently dismissed for any reason 0r fails to callany designated expert at the time of trial, Defendant specifically reserves the right t0 call any such expert previously designated by that party. DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1- Defendant further reserves the right t0 withdraw 0r de-designate any expert prior t0 testimony and to positively aver that such previously designated expert Will not be called as a Witness at trial and t0 redesignate same as a consulting expert Who will not be called by any party in this cause. Finally, Defendant reserves the right t0 supplement this response as additional information concerning experts becomes available. Defendant further hereby designates as adverse expert witnesses all expert Witnesses designated by Plaintiffs. Defendant reserves the right t0 rely upon 0r t0 offer, by direct examination or cross—examination, testimony obtained from those experts and rebuttal experts, if any, designated by Plaintiffs. By this designation, Defendant does not necessarily agree With, nor vouch for, the credibility 0f any such Witnesses 0r their opinions, or the reliability, materiality, 0r admissibility of information and/or tangible things produced by these individuals in general; by this designation Defendant is simply reserving the opportunity t0 rely upon 0r elicit certain opinions and/or evidence from these witnesses t0 the extent that it deems it in its interest t0 d0 s0. Such persons are expected t0 testify concerning Plaintiffs’ care and treatment. See Plaintiffs’ Responses t0 Defendant’s Request for Disclosure for additional information concerning such health-care providers including medical bills and records relating to Plaintiffs. First Supplemental Response: Defendant hereby designates as an expert witness the following individual: Andrew Goodman, DC 2046 Forest Lane, Ste. 180 Garland, Texas 75042 972.265.8104 Dr. Goodman is chiropractor who has reviewed Abram Montemayor’s medical records and other case materials provided t0 him and is expected t0 testify regarding the extent of the injuries sustained by the Plaintiff in the subj ect motor vehicle accident, the appropriate care and treatment for those injuries, and the fair and reasonable cost 0f that treatment, both in the past and in the future, if applicable, as set out in the attached report. Andrew Goodman, DC 2046 Forest Lane, Ste. 180 Garland, Texas 75042 972.265.8104 Dr. Goodman is chiropractor who has reviewed Enrique Montemayor’s medical records and other case materials provided t0 him and is expected t0 testify regarding the extent 0f the injuries sustained by the Plaintiff in the subj ect motor vehicle accident, the appropriate DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2- care and treatment for those injuries, and the fair and reasonable co st of that treatment, both in the past and in the future, if applicable, as set out in the attached report. Respectfully submitted, ¢f/fl Chad Kimble, Bar N0. 24007483 State Kyle Smith, State Bar N0. 24102512 D. Brent Beasley, State Bar N0. 24082669 LAW OFFICE 0F CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE The undersigned celtifies that 0n the 20th day of May, 2020, a true copy of the foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. Kyle Smith DEFENDANT’S FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3- ANDREW GOODMAN, D.C. 12001 N. CENTRAL EXPRESSWAY DOCTOR 0F CHIROPRACTIC SUITE 800 DALLAS, TX 75243 (214) 750-61 10 FAX - (214) 750—5825 May 15, 2020 Mr. Chad Kimble Law Office of Chad Kimble 1204 South White Chapel Blvd. Southlake, TX 76092 RE: Abram Montemayer CLAIM #: 0550252365 DATE OF INJURY: 06/18/19 CASE #: 21118418 Dear Mr. Kimble: | have had the opportunity to review medical records on Mr. Abram Montemayer. My name is Andrew Goodman, DC. Cum Laude from Parker College of Chiropractic in 2008. | graduated | have had chiropractic practices and Dallas, TX seeing and treating many patients who were in Plano, TX subject to musculoskeletal injuries of the spine and the extremities. was also the Director of Rehabilitation for | Alpha Physical Medicine, the rehabilitation center for Alpha Orthopedics, seeing and treating hundreds of post- operative and non-operative patients, many of whom were injured due to traumatic incidences of falls, motor vehicle accidents, and fractures. have had direct patient experience with thousands of patients during my | time as a Doctor of Chiropractic. maintain an active license and work as an independent contractor for an | occupational medicine performing pre-employment physicals, Department of Transportation physicals, clinic and workers’ compensation injuries and independent medical evaluations to determine MMI and assign impairment ratings. am a Nationally Registered Certified Medical Examiner for the Department of | Transportation and a certified Designated Doctor with the Texas Department of Insurance Division of Workers’ Compensation. have several years of experience setting fee schedules, billing third-party reimbursement and | discussing third-party reimbursement with patients. OVERVIEW: On June 18, 2019, the patient was involved in a motor vehicle accident. On June 20, 2019, the patient Injury Care Auto & Work Chiropractic for an initial examination presented to complaining of neck pain and numbness and tingling of the upper extremities, mid back pain, low stiffness, back pain with numbness and tingling of the lower extremities, left hand and left wrist severe pain, left knee pain and discomfort. Cervical spine range of motion is restricted in flexion, extension and rotation bilaterally. Lumbar spine range of motion is decreased in flexion, extension, rotation and side bending. Left wrist range of motion is decreased. Compression negative in the cervical spine, Adson's maneuver is negative in the cervical spine, shoulder test is depression test is negative in the cervical spine, Soto-Hall test is negative in the cervical spine. Lasegue straight leg test is negative in the lumbar spine. Patrick-Faber test is negative in the lumbar spine. Kemp’s test is negative in the lumbar spine. Yeoman’s test is negative in the lumbar spine. Ely’s and hyperextension test of the lumbar spine are negative. Phalen’s test is negative in the left wrist. Tinel’s test is negative in the left wrist. Finkelstein’s is negative in the left wrist. Treatment in this date consisted of cold therapy, traction, EMS, massage and therapeutic activities. Abram Montemayer May 15, 2020 CASE #: 21118418 Page 2 of 7 On June 21, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment. Treatment consisted of cold therapy, traction, EMS, massage and therapeutic activities. On June 26, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment consisting of cold therapy, traction, EMS, massage and therapeutic activities. On June 28, 2019, the patient had x-rays of the left knee with the following impression, no acute radiographic abnormality. Patient had x-rays of the lumbar spine with the following impression, no radiographic abnormality of the lumbar spine. Patient had thoracic spine x-rays with the following impressions, no radiographic abnormality of the thoracic spine. X-rays of the lumbar spine for the patient revealed the following impressions, loss of lordotic curve, possible mild retrolisthesis at L5-S1. No evidence of fracture or osseous destructive lesion. Patient had x-rays of the left hand with the following impression: A fifth metacarpal base fracture. Patient had x-rays of the cervical spine with the following impression: No acute finding demonstrated. Thoracic spine x-rays for the patient revealed the following impression: Thoracic spine is within normal limits. Right knee x-rays revealed the following impression for the patient: Right knee is within normal limits. On June 28, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, massage and therapeutic exercise. On July 1, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, mechanical traction, EMS, therapeutic activities and manipulation. On July 3, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation. On July 5, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On July 8, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation. On July 11, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On July 15, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, manual traction, therapeutic activities and manipulation. On July 17, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation. On July 18, 2019, the patient presented to DFW MRI for an MRI of the lumbar spine with the following impression, no acute fracture evidence, stress injury or spondylolisthesis, straightening of normal lumbar lordosis, which could be positional or due to lumbar strain, these clinically correlate. On July 23, 2019, the patient presented to DFW MRI for an x-ray of his left hand with the following impressions, minimally displaced healing fracture involving the base of the fifth metacarpal. On July 23, 2019, the patient presented for left wrist x-rays with the following impressions, no acute osseous abnormality. Abram Montemayer May 15, 2020 CASE #: 21 1 18418 Page 3 of 7 On July 24, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation. On July 25, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction and EMS. On July 29, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction and manipulation. On July 31, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of heat therapy, mechanical traction, EMS, therapeutic activities, manual traction and manipulation. On August 2019, the patient presented to Injury Care Auto 2, & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, and ultrasound. On August 5, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, manipulation, and extremity manipulation. On August 7, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation. On August 12, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of manual traction, manipulation of the spine and extremity manipulation. On August 19, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of manual traction, manipulation of the spine and manipulation of the extremities. On August 26, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of manual traction, manipulation of the spine and manipulation of the extremities. On September 4, 2019, the patient presented to Injury Care Auto & Work Chiropractic for treatment, which consisted of manual traction, manipulation of the spine and manipulation of the extremities. On September 23, 2019, the patient presented to Injury Care Auto & Work Chiropractic for final evaluation and on this date, the patient was released from care. RESPONSEIOPINION: The following opinion is based upon my education, treatment experience and commonly accepted chiropractic treatment guidelines. have had direct patient experience with thousands of patients during my | time as a Doctor of Chiropractic. maintain an active license and work as an independent contractor for an | occupational medicine clinic where perform pre-employment physicals, Department of Transportation | physicals, and Workers' Compensation injuries. am a Nationally Registered Certified Medical Examiner for the | Department of Transportation and a certified Designated Doctor with the Texas Department of Insurance Division of Workers' Compensation. have several years of experience setting fee schedules, billing third-party | reimbursement and discussing third-party reimbursement with patients. The patient was involved in a motor vehicle accident on June 18, 2019. On June 20, 2019, the patient presented to Injury Care Chiropractic for initial evaluation. The patient’s initial evaluation is suggestive of signs and symptoms that are consistent with cervical, thoracic and lumbar strains and sprains, status post motor vehicle collision. This type of treatment qualifies for an initial trial of care of 6 visits over the course of 2 weeks at which point a re-examination should be performed to determine a functional progress is being achieved. The Abram Montemayer May 15, 2020 CASE #: 21118418 Page 4 of 7 sixth visit took place on July 1, 2019, however, at no point during the patient’s plan of care was a re- examination ever performed based on the documentation provided. Therefore any and/or chiropractic services and treatments should have stopped after the sixth visit on July 1, 2019. The following charges are not reasonable, based on usual and customary rates with regard to similar changes provided in that geographic region. CPT code 97010, hot/cold pack was billed $15, this should not have been billed, as this type of treatment is not indicated to be clinically efficacious. CPT code 97012, mechanical traction was billed $65, should not have been billed more than $32. CPT code 97032, electrical muscle stimulation was billed $65, should not have been billed more than $31. CPT code 97110, therapeutic exercise billed $80 per unit, should not have been billed more than $64 per unit. CPT code 97140, manual therapy was billed $80 per unit, should not have been billed more than $59 per unit. CPT code 98940, manipulation in one or two areas was billed $135, should not have been billed more than $59. CPT code 97124, massage was billed $75, should not have been billed more than $61. CPT code 99203 was billed $260, this is improper use of evaluation and management coding, this was not billed on the first visit date, but on the third visit date, it should have been billed on the first visit date and should not have been billed more than $220. CPT code 99213 was billed $110 this is improper use of evaluation and management coding as there is no evidence to support that an examination of this level was performed on June 26, 2019. CPT code 97035, ultrasound was billed $65, should not have been billed more than $30. CPT code 98943, extremity manipulation was billed $80, should not have been billed more than $57. CPT code 99214, re-examination was billed $165, this is improper use of evaluation and management coding as there is no documentation to support that an exam of this level was performed on the following dates of August 7, 2019 and August 12, 2019. Patient had a lumbar MRI performed. Based on the records provided, this was a referral that was made on the initial evaluation at Injury Care Chiropractic. This referral for an MRI is not necessary for this patient. The patient did not have any orthopedic findings such as a positive Lasegue straight leg raise and 0-30 degrees with radicular pain going from the low back down the lower extremity. There is no documentation of a loss of reflex from one side to the other nor is there a documentation of any muscle weakness and this type of documentation would be needed to necessitate a referral for an MRI to evaluate for any type of soft tissue injury occurring in the lumbar spine because none of that documented anywhere in the patient’s chart. The lumbar MRI is not necessary for this patient. The lumbar MRI CPT code 72148 was billed $3012, this should not have been billed more than $463. To calculate fees, I utilized an average of what providers in that geographic region charge. The following is an opinion on future treatment and costs based on the records provided. In my opinion, there is no need for any future treatment and there should be no future treatment costs for this patient based on the injuries sustained in the motor vehicle accident; Thank you for the opportunity to review the medical records on Mr. Abram Montemayer. Dictated, reviewed, opinion verified, and attested to by my original signature. Sincerely, 5%; Andrew Goodman, D.C. Doctor of Chiropractic 11008 AG/sm/ANS/lea Abram Montemayer May 15, 2020 CASE #: 21118418 Page 5 of 7 The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the basis of the medical records provided, with the assumption that the material is true and correct. If more information becomes available at a later date, an additional service/report/reconsideration may be requested. Abram Montemayer May 15, 2020 CASE #: 21118418 Page 6 of 7 SUMMARY OF RECORDS • Texas Peace Officer’s Crash Report, 06/18/19 • Injury Care Auto & Work Chiropractic, Margarita Pena-Obando, D.C., 06/20/19, 06/21/19, 06/26/19, 06/28/19, 07/01/19, 07/03/19, 07/05/19, 07/08/19, 07/11/19, 07/15/19, 07/17/19, 07/24/19, 07/25/19, 07/29/19, 07/31/19, 08/02/19, 08/05/19, 08/07/19, 08/12/19, 08/19/19, 08/26/19, 09/04/19, 09/23/19, 10/02/19 • DFW Open MRI, Michael Lloyd, M.D./James Schroeder, M.D./Mumtaz Syed, M.D./Joel Carp, M.D./Solomon Bierman, M.D., 06/28/19, 07/18/19, 07/23/19, 09/09/19 • O’Reilly Auto Parts, 07/01/19, 07/08/19 • AM/PM Medical Centers, Philip Rodriguez, F.N.P., D.C., 07/11/19, 08/02/19 • Comprehensive Spine Center, Scott Farley, D.O./Phat Truong, P.A.-C., 07/16/19, 08/06/19, 08/13/19, 09/20/19 • Plaintiff’s Responses to Defendant’s Request for Disclosure, 04/30/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, AM/PM Medical Centers, 03/06/20 • Affidavit of Medical Records, AM/PM Medical Centers, 03/06/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, ASP Cares Pharmacy, 03/05/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, Comprehensive Spine Center of Dallas, 03/09/20 • Affidavit of Medical Records, Comprehensive Spine Center of Dallas, 03/09/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, DFW Open MRI, 03/06/20 • Affidavit of Medical Records, DFW Open MRI, 03/06/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, Injury Care Chiropractic, 03/04/20 • Affidavit of Medical Records, Injury Care Chiropractic, 03/04/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, Metroplex DME, 03/09/20 • Affidavit of Medical Records, Metroplex DME, 03/09/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, PeopleFirst Pharmacy, 03/10/20 • Affidavit Establishing Necessity and Reasonableness of Services and Charges, Singleton Associates, P.A., 03/16/20 • Plaintiff Abram Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20 • Plaintiff Enrique Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20 • Plaintiff Abram Montemayor’s Objections and Responses to Defendant’s Request for Production, 04/30/20 • Plaintiff Enrique Montemayor’s Objections and Responses to Defendant’s Request for Production, 04/30/20 • Color Photographs, 10 pages • Itemized Statement, AM/PM Medical Centers, Date of Service, 07/11/19-08/02/19 • Itemized Statement, Patient Profile Report, ASP Cares, Date of Service, 07/16/19-07/17/19 • Itemized Statement, Comprehensive Spine Center, Dates of Service, 07/16/19-09/20/19 • Health Insurance Claim Form, Comprehensive Spine Center, Phat Truong, N.P.-C., 07/16/19, 08/06/19, 08/13/19, 09/20/19 • Itemized Statement, DFW Open MRI, Dates of Service, 06/28/19-09/09/19 • Health Insurance Claim Form, DFW Open MRI, 06/28/19, 07/18/19, 07/23/19, 09/09/19 • Itemized Statement, Injury Care Chiropractic, Dates of Service, 06/20/19-09/23/19 • Payment Inquiry, O’Reilly Auto Parts, Dates of Service, 12/06/18-09/26/19 • Itemized Statement, Metroplex DME, Date of Service, 07/16/19 • Health Insurance Claim Form, Metroplex DME, Scott Farley, D.O., 07/16/19 • Itemized Statement, PeopleFirst Pharmacy, Date of Service, 07/15/19 • Itemized Statement, Singleton Associates, Dates of Service, 06/28/19-09/09/19 Abram Montemayer May 15, 2020 CASE #: 21118418 Page 7 of 7 • Itemized Statement, AM/PM Medical Centers, Date of Service, 07/11/19 • Itemized Statement, DFW Open MRI, Date of Service, 06/28/19-07/18/19 • Itemized Statement, Injury Care Chiropractic, Dates of Service, 06/20/19-10/02/19 • Itemized Statement, Singleton Associates, Dates of Service, 06/28/19-07/18/19 ANDREW GOODMAN, D.C. 12001 N. CENTRAL EXPRESSWAY DOCTOR OF CHIROPRACTIC SUITE 800 DALLAS, TX 75243 (214) 750—61 10 FAX — (21 4) 750-5825 May 15, 2020 Mr. Chad Kimble Low Office of Chad Kimble, PC 1204 S. Whi’re Chapel Blvd. Sou’rhloke, TX 76092 RE: Enrique Mon’remoyor CLAIM#: 0550252365 DATE OF INJURY: 06/18/19 CASE#: 21 18428 1 Dear Mr. Kimble: | hove had The opportunity ’ro review medical records on Mr. Enrique Mon’remoyor. My name is Andrew Goodman, DC. | graduated Cum Loude from Parker College of Chiroproc’ric in 2008. | hove had chiropractic practices 0nd Dallas, TX seeing 0nd Treating many po’rien’rs who were in Plano, TX subjec’r ’ro musculoskele’rol injuries of ’rhe spine 0nd The ex’rremi’ries. was also ’rhe Director of Rehabilitation for | Alpha Physical Medicine, ’rhe rehabilitation cen’rer for Alpha Orthopedics, seeing 0nd Treo’ring hundreds of pos’r- operative 0nd non-opero’rive po’rien’rs, many of whom were injured due ’ro Traumatic incidences of falls, mo’ror vehicle occiden’rs, 0nd froc’rures. hove had direct po’rien’r experience wi’rh Thousands of po’rien’rs during my | ’rime as o Doc’ror of Chiropractic. moin’roin on oc’rive license 0nd work Gs on independent confroc’ror for on | occupo’rionol medicine clinic performing pre-employmen’r physicals, Depor’rmen’r of Tronspor’ro’rion physicals, 0nd workers’ compensation injuries 0nd independent medical evaluations ’ro de’rermine MMI 0nd assign impairment ro’rings. om c1 Nationally Registered Certified Medical Examiner for ’rhe Deportmen’r of | Transportation cmd c1 certified Designated Doc’ror wi’rh ’rhe Texas Department of Insurance Division of Workers’ Compenso’rion. | hove several years of experience se’r’ring fee schedules, billing Third-por’ry reimbursement 0nd discussing Third-por’ry reimbursement wi’rh po’rien’rs. OVERVIEW On June presented To Injury Core Au’ro & Work Chiropractic for on ini’riol visi’r. The po’rien’r 20, 2019, The pofien’r complained neck pain 0nd stiffness, numbness 0nd Tingling of The upper extremities, mid back pain, low of back pain wi’rh numbness 0nd Tingling in The lower extremities, Ief’r elbow pain, righ’r wris’r pain, 0nd bilo’rerol knee pain. Cervical range of mo’rion wos restricted in flexion, extension, 0nd ro’ro’rion bilo’rerolly 0nd Io’rerol flexion. Compression ’res’r wos negative, Adson’s maneuver wos negative, shoulder depression Tes’r wos nego’rive, 0nd So’ro—Holl Test was negative. The lumbar spine had decreased rcmge of mo’rion in flexion, extension, ro’rofion, 0nd Io’rerol flexion. Loségue’s straight leg raise ’resT wos negative. Po’rrick/Fober ’resT wos nego’rive. Kemp’s Test wos negative. Yeomon’s Tes’r was negative. Ely’s hyper—exfension of The lumbar spine was negative. Lef’r elbow range of mo’rion was normal. Cozen’s ’res’r wos negative. Mill’s ’res’r wos negative. Righ’r wris’r range of mo’rion was wi’rhin normal wos negative. Tinel’s ’res’r wos negative. limi’rs. Pholen’s ’res’r Finkelstein’s wos negative. ’res’r knee examination range of mo’rion wos wi’rhin normal limi’rs. Volgus Bilo’rerol 0nd vorus s’rress ’res’rs negative, Drawer ’res’r negative, McMurroy’s ’res’r were negative. Reflexes were normal cmd normal sensation ’ro pinprick. Treatment on This date consisted of cold Therapy, mechanical Troc’rion, EMS (electrical muscle stimulation), massage, 0nd Therapeutic oc’rivi’ries. On June 21, 2019, The potien’r presented ’ro Injury Core Chiroproc’ric for Treatment which consis’red of cold ’rheropy, ’rroc’rion, EMS, massage, 0nd Therapeutic oc’rivi’ries. Enrique Montemayor May 15, 2020 CASE#: 21118428 Page 2 of 5 On June 24, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On June 26, 2019, the patient presented to Injury Care Auto and Work Chiropractic for treatment which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On June 28, 2019, the patient presented to DFW MRI for lumbar spine x-rays with the following impressions: No radiographic abnormality of the lumbar spine. The patient also presented for left elbow x-rays with the following impression: No acute radiographic abnormality. The patient had right hand x-rays with the following impression: No acute radiographic abnormality. The patient had cervical spine x-rays with the following impression: No acute radiographic abnormality of the cervical spine. The patient had mid-back x-rays with the following impression: No radiographic abnormality of the thoracic spine. The patient had right knee x-rays with the following impression: No acute radiographic abnormality. The patient had left knee x-rays with following impression: No acute radiographic abnormality. On June 28, 2019, the presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On July 1, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation. On July 3, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation. On July 5, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, and EMS. On July 8, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, manual traction, and manipulation. On July 10, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation of the spine and manipulation of the left knee. On July 11, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, massage, and therapeutic activities. On July 17, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, and manipulation. On July 18, 2019, the patient presented to DFW MRI for an MRI of the left knee with the following impressions: No MRI abnormality of the left knee. On July 24, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, traction, EMS, therapeutic activities, manual traction, manipulation, and manipulation of the left knee. On July 31, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, mechanical traction, EMS, therapeutic activities, ultrasound, manual traction, and manipulation. On August 2, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat therapy, mechanical traction, EMS, therapeutic activity, and ultrasound. Enrique Montemayor May 15, 2020 CASE#: 21118428 Page 3 of 5 On August 5, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of cold therapy, EMS, therapeutic activities, manual traction, and manipulation. On August 7, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual traction, manipulation of the spine and manipulation of the left knee. On August 15, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat therapy, EMS, and ultrasound. On August 23, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of heat therapy and EMS. On August 26, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual traction, spine manipulation, and left knee manipulation. On September 4, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual traction and manipulation. On October 2, 2019, the patient presented to Injury Care Chiropractic for treatment which consisted of manual traction and on this date the patient had a final examination and was released from care. DISCUSSION/OPINION The following opinion was based upon my education, treatment experience, and commonly accepted chiropractic treatment guidelines. I have had direct patient experience with thousands of patients during my time as a Doctor of Chiropractic. I maintain an active license and work as an independent contractor for an Occupational Medicine Clinic, where I perform pre-employment physicals, Department of Transportation physicals, and Workers' Compensation injuries. I am a Nationally Registered Certified Medical Examiner for the Department of Transportation and a certified Designated Doctor with the Texas Department of Insurance Division of Workers' Compensation. I have several years of experience setting fee schedules, billing third-party reimbursement and discussing third-party reimbursement with patients. With regard to the necessity of treatment at Injury Care Chiropractic, the patient was involved in a motor vehicle accident on June 18, 2019. On June 20, 2019, the patient presented to Injury Care Chiropractic for treatment with an initial examination suggestive of cervical, thoracic, and lumbar strains and sprains as well as extremity contusions of the knees and right wrist and left elbow. This type of treatment, as it relates to the spine, qualifies for a trial of care consisting of six visits over the course of two weeks after which a re-examination should be performed to establish if functional progress is being achieved. The initial examination and visit was on June 20, 2019. The sixth visit took place on July 1, 2019. However, there was not a re-examination performed on that sixth visit on July 1, 2019, and there was not a re-examination performed at any point during the patient’s plan of care. Therefore, because there was no re-examination performed on the sixth visit on July 1, 2019, or any other time during the patient’s plan of care, all chiropractic care should have ceased after the visit on July 1, 2019. Following is an opinion on the reasonableness of charges and pricing from Injury Care Chiropractic. To calculate fees, I utilized an average of what providers in that geographic region charge. The following charges are not reasonable with regard to usual and customary rates for similar services performed in a similar geographic region: CPT Code 97010, hot and cold pack was billed $15, this should not have been billed as this type of treatment is not indicated to be clinically efficacious. CPT Code 97012, mechanical traction was billed $65, this should not have been billed more than $32. Enrique Montemayor May 15, 2020 CASE#: 21118428 Page 4 of 5 CPT Code 97032, electrical muscle stimulation was billed $65, this should not have been billed more than $31. CPT Code 97124, mechanical massage was billed $75, this should not have been billed more than $61. CPT Code 97112, therapeutic activities was billed $80, this should not have been billed more than $64. CPT Code 99203, initial examination was billed $260. This is an improper use of evaluation and management coding. This was billed on June 24, 2019, which was actually the third visit which should have been billed on the first visit and should not have been billed more than $220. CPT Code 99213, established patient re-examination was billed $110, this should not have been billed as there was no evidence to support that an examination of this level took place on the date of June 26, 2019. CPT Code 98940, manipulation of one to two regions of the spine was billed $135, this should not have billed more than $59. CPT Code 97140, manual therapy was billed $80, this should not have been billed more than $58. CPT Code 98943, extra-spinal manipulation was billed $80, this should not have been billed more than $57. CPT Code 99214, established patient re-examination was billed $165. This is an improper use of evaluation and management coding as there was no evidence to support that a re-examination was performed on this date at this level on August 7, 2019. With regard to the necessity of the referral of the MRIs at DFW MRI, on July 18, 2019, the patient presented for an MRI of the left knee. This referral for a left knee MRI was not necessary for this patient. Based on the records provided, the patient never had any soft tissue injuries that would warrant additional imaging beyond an x-ray. There was no documentation of swelling, no documentation of orthopedic findings that would be indicative of soft tissue injury such as a positive McMurray’s test, positive Lachman’s, or positive Drawer tests that would indicate that some type of ligamentous or soft tissue injury has occurred and qualifies for additional imaging. None of this was documented anywhere in the patient’s records. Therefore, the left knee MRI was not necessary for this patient. The following is an opinion on the reasonableness of the charges for the MRI at DFW MRI. The following charge is unreasonable as it relates to similar charges in that geographic region: CPT Code 73721, left knee MRI was billed $2,620, this should not have been billed more than $475. The following opinion is regarding future treatment and costs based on the injuries sustained by the patient from this motor vehicle accident. My opinion is that there is no need for any future treatment and no future costs as it relates to injuries sustained by the patient from this motor vehicle accident. Thank you for the opportunity to review the medical records on Mr. Enrique Montemayor. Dictated, reviewed, opinion verified, and attested to by my original signature. Sincerely, 6%4/ Andrew Goodman, D.C. Doctor of Chiropractic 11008 AG/kf/ANS/str The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the basis of the medical records provided, with the assumption that the material is true and correct. If more information becomes available at a later date, an additional service/report/reconsideration may be requested. Enrique Montemayor May 15, 2020 CASE#: 21118428 Page 5 of 5 SUMMARY OF RECORDS Texas Peace Officer’s Crash Report, 06/18/19 Injury Care Auto & Work Chiropractic, Margarita Pena Obando, D.C., 06/18/19, 06/20/19, 06/21/19, 06/24/19, 06/26/19, 06/28/19, 07/01/19, 07/03/19, 07/05/19, 07/08/19, 07/10/19, 07/11/19, 07/17/19, 07/24/19, 07/31/19, 08/02/19, 08/05/19, 08/07/19, 08/15/19, 08/23/19, 08/26/19, 09/04/19, 10/02/19 DFW MRI, Michael Lloyd, M.D., 06/28/19, 07/18/19 AM PM Medical Centers, Phillip Rodriguez, F.N.P. D.C., 07/11/19 Plaintiff’s Responses to Defendant’s Request for Disclosure, 04/30/20 Affidavit Establishing Necessity and Reasonableness of Services and Charges, AM/PM Medical Centers, 03/06/20 Affidavit for Medical Records, AM/PM Medical Centers, 03/06/20 Affidavit Establishing Necessity and Reasonableness of Services and Charges, DFW Open MRI, 03/06/20 Affidavit for Medical Records, DFW Open MRI, 03/06/20 Affidavit Establishing Necessity and Reasonableness of Services and Charges, Injury Care Chiropractic, 03/04/20 Affidavit for Medical Records, Injury Car Chiropractic, 03/04/20 Affidavit Establishing Necessity and Reasonableness of Services and Charges, Singleton Associates, P.A., 03/10/20 California Jurat, 03/16/20 Plaintiff Abram Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20 Plaintiff Enrique Montemayor’s Answers to Defendant’s First Set of Interrogatories, 04/30/20 Plaintiff Abram Montemayor’s Objections and Responses to Defendant’s Request for Production, 04/30/20 Plaintiff Enrique Montemayor’s Objections and Responses to Defendant’s Request for Production, 04/30/20 Color Vehicle Photographs, 9 pages Itemized Statement, AM PM Medical Centers, Statement Date, 08/06/19; Dates of Service, 07/11/19 Itemized Statement, DFW Open MRI, LP, Statement Date, 03/05/20; Dates of Service, 06/28/19 – 07/18/19 Health Insurance Claim Form, DFW MRI Garland, 06/28/19, 07/18/19 Itemized Statement, Injury Care Chiropractic, Statement Date, 10/11/19; Dates of Service, 06/20/19 – 10/02/19 Itemized Statement, PeopleFirst Pharmacy, Statement Date, 03/10/20; Dates of Service, 07/15/19 Itemized Statement, Singleton Associates, PA, Statement Date, 03/16/20; Dates of Service, 06/28/19 – 07/18/19 Andrew Goodman, D.C. Dallas, TX 75248 PROFESSIONAL SUMMARY Extensive experience building patient relationships and delivering exceptional medical care as part of a collaborative medical team o Promoted health and wellness as a licensed chiropractor, addressing a wide range of medical problems. o Developed multiple partnerships with doctors and specialists to address patient total wellbeing. o High academic success and strong marks and reviews earned on all clinical rotations. o Thrive in fast paced medical environments. Enjoy problem solving to answer tough problems. CHIROPRACTIC EXPERIENCE Chiropractor/Health Care Provider, Occumed Plus, Dallas, September 2017 — Present TX Performed pre-employment assessments and ongoing medical examinations for the Department of Transportation. Evaluated, diagnosed, and documented acute care management for work related injuries. Communicated work restrictions, improvements, and assigned impairment ratings. Designated Doctor/lndependent Peer Reviewer, Exam Works, March 2018 — Present