Preview
FILED
8/24/2020 9:50 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
No. DC-20-04806
Cause N0. DC-20-04806 Martin Reyes
TINA ARMSTRONG s DISTRICT COURT OF
IN THE DISTRICT
$
s
YS.
vs. $
Cmmwiwmwom
DALLAS COUNTY,
COUNTY, TEXAS
$
DOLGENCORP OF TEXAS, INC.
INC. $
D/B/A DOLLAR GENERAL STORE
D/B/A s JIJDICIAL DISTRICT
1O1ST JUDICIAL
lOIST DISTRICT
OF INTENTION
NOTICE 0F PRODUCTION OF DOCUMENTS
INTENTION FOR PRODUCTION
TO:
TO: ATTORNEY(S) OF
ALL PARTIES BY AND THROUGH THEIR ATTORNEY(S) IN THE ATTACHED
AS PROVIDED IN
OF RECORD AS ATTACHED
LIST.
SERVICE LIST.
SERVICE
will take
You will thatten
notice that
take notice (10) days
ten (10) afterthe
days after the service the custodian
hereof, the
service hereof, ofrecords
custodian 0f for:
records for:
PARKLAND HEALTH & HOSPITAL SYSTEM—(Medical Records)
SYSTEM-(Medical Records)
HEALTH INFORMATION MANAGEMENT DEPARTMENT
HEALTH DEPARTMENT
5201 TX75235
52OT HARRY HINES BLVD, DALLAS, TX 75235
receive aa
Shall receive
Shall Subpoena to to produce
produce documents
documents 0n after 09/10/2020,
on after 09/10/2020, 0r or any
any other time and/or
other agreed upon time place, before
and/or place, before a
Public at
Notary Public
Notary the instance
at the of:
instance of:
Written Deposition
Written Service, LLC
Deposition Service,
Whittington Place,
1755 Whittington Place, Suite
Suite 750
.
Dallas, TX
Dallas, TX75234
75234
or its
or its designated to be
agent, t0
designated agent, in evidence
be used in evidence upon the trial 0f
the trial of the
the above-styled
above-styled and numbered cause pending in the
pending in the above
namedcourt.
named court. Notice is further given that request is hereby made as authorized under Rule 205.2 & 205.3, Texas Rules of
NoticeisfurthergiventhatrequestisherebymadeasauthorizedrmderRule205.2&.205.3,TexasRulesof
Civil Procedure,
Civil Procedure, that
that the
the officer shall
authorized officer
authorized issue aa Subpoena Duces
shall issue Duces Tecum and
and cause it to
cause it to be
be served the witness
served on the to
witness to
produce any and
produce any and all records
all records as described on
as described the attached
on the attached Subpoena(s)
Subpoena(s) and/or Exhibit(s) and
and/or Exhibit(s) any other
and any other such record in the
record in the
possession, custody
possession, or control
custody or control of
of the
the said witness, and every
said witness, record t0
every such record to which the
the witness
witness may have access, pertaining t0:
access, pertaining to:
TINA DARSELL ARMSTRONG
TINA ARMSTRONG and to turn
and t0 all such
turn all records over
such records to the
over to the authorized officer sb
authorized officer so that
that photographic
photographic
of the
reproductions of
reproductions attached.
the same may be made and attached.
Respectfu lly Submitted,
Respectfully Submitted,
/s/P.
/s/P. Murcus White
Marcus White
P.
P. White
Marcus White
#: 24061263
SBA #:
Whitehurst & Cawley,
Whitehurst Cawley, LLP
Addison Road,
16300 Addison Road, Suite
Suite 100
Addison, TX 75001
Addison,
972-503-5455; Fax 972—503-6155
972-503-5455; 912-503-6155
mwhite@whitehurstlaw.com
mwhite@whitehurstlaw.c0m
Attorney
Attorney for: Defendant
for:
CERTIFICATE OF SERVICE
CERTIFICATE
I certify,
I certi$r, as
as authorized
authorized agent for the
agent for the attorney of record,
attorney 0f P. Marcus
record, P. White that
Marcus White that aa true
true and of
copy 0f
exact copy
and exact
foregoing Notice
foregoing of Intention
Notice of for the
Intention for the Production of
Production 0fDocuments was was served to all
served to all attorneys of record
attorneys of in the
record in the
above-styled and numbered
above-styled matter, said
numbered matter, said service being effected
service being effected in
in the following manner:
the following manner:
MAIL/RETURN RECEIPT REQUESTED
CERTIFIED MAIL/RETURN REQUESTED
}IAND DELIVERY
HAND
TELECOPY
OVERNIGHTA{EXT DAY DELIVERY
OVERNIGHT/NEXT DELTVERY VIA LONE STAR OR UPS
E-MAIL
E-FILE
DATED:
BY
SERVED TO ALL PARTIES LISTED
SERVED LISTED BELOW:
Armstrongvs.
Tina Armstrong
Tina Dolgencorp ofTexas,
vs. Dolgencorp Inc. d/b/a
of Texas, Inc. Dollar General
d/b/a Dollar General Store
Store
ATTORNEYS OF RECORD
OFRECORD
Grifhn Scheumack
Griffin
Abbott & Associates
Ben Abbott Associates
Drive
Pendleton Drive
1934 Pendleton
Garland, TX 75041
Garland, TX 75041
9'72-263-5555; Fax:
972-263-5555; Fax:
Attorney For:
Attorney Plaintiff
For: Plaintiff
SUBPOENA DUCES TECUM
THE STATE OF TEXAS
County 0f
County of Dallas
Dallas
Greeting, 1o
Greeting, to any Sheriff or
any Sheriff or Constable of the
Constable of the State of Texas
State 0f Texas or_ other person
or other person authorized
authorized to
to serve of
Rule 1766 0f
serve subpoenas under Rule lj
Texas Rules 0f Civil Procedure:
of Civil Procedure: You are hereby commanded
are hereby commanded t0 to subpoena and summon
summon the following witness(es):
the following witness(es):
Designated Custodian 0f
nated Custodian of Records for: PARKLAND
for: &
HEALTH &
PARKLAND HEALTH HOSPITAL
SYSTEM
ls)‘e{ssi
to be
t0 before aaNotary
and appear before
be and Notary Public of
Public of designation for
my designation Written Deposition
for Written Deposition Service, LLC, 1755
Service, LLC, Whittington Place,
lTSS Whittington Place,
Suite 750,
Suite Dallas,
750, Dallas, TX
TX '75234, 0n
75234, or
on or after
after 09/10/2020, at the
0911012020, at office 0f
the office of the
the summoned
summoned witness.
witness. There to bring
There to bring and produce for
produce for
inspection and
inspection ANY
and photocopying ALL MEDICAL RECORDS (EXCLUDING BILLING RECORDS), FROM
ANY AND ALL
photocopying
2I5I2OI4
2/5/2014TO PRESENT,
TO PRESENT, INCLUDING BUT NOT
INCLUDING BUT LIMITED TO
NOT LIMITED TO RECORDS
RECORDS REGARDING THE PATIENT'S
REGARDING THE
CONDITIONS AND TREATMENTS,
CONDITIONS TREATMENTS, DOCTOR'S NOTES, EVALUATIONS, OFFICE NOTES, PROGRESS NOTES,
AUDIT REPORTS,
AUDIT REPORTS, CORRESPONDENCE WITH OTHER
CORRESPONDENCE WITH OTHER PHYSICIANS,
PHYSICIANS, THERAPISTS, HOSPITALS
HOSPITALS AND/OR
AND/OR
HEALTHCARE PROVIDERS, PHYSICAL THERAPY RECORDS, RECORDS, LAB REPORTS, RADIOLOGY REPORTS, ALL
OTHER DIAGNOSTIC
DIAGNOSTIC REPORTS, PRESCRIPTIONS,
PRESCRIPTIONS, REFERRALS T0 TO OTHER HEALTH CARE PROVIDERS,
PROVIDERS,
CLAIMS, WORKER'S
CLAIMS, WORKER'S COMPENSATION
COMPENSATION RECORDS, HOSPITAL RECORDS,
RECORDS, HOSPITAL RECORDS, THERAPISTS'
THERAPISTS' RECORDS,
PATIENT INFORMATION
PATIENT INFORMATION FORMS, PATIENT INSURANCE
FORMS, PATIENT INSURANCE FORMS, FORMS, INTAKE FORMS, FORMS, LITIGATION FILES,
FILES,
HANDWRITTEN NOTES, LETTERS OF PROTECTION,
PROTECTION, TELEPHONE
TELEPHONE MESSAGES,
MESSAGES, NURSES'
NURSES'NOTES,
NOTES, EVERY
SUCH RECORD, LIMITED TO,
RBCORD, INCLUDING BUT NOT LIMITED TO, THOSE
THOSE EXISTING IN IN ELECTRONIC 0ROR MAGNETIC
FORM, INCLUDING
FORM, CORRESPONDENCE IN THE POSSESSION, CUSTODY
INCLUDING CORRESPONDENCE IN THE CUSTODY OR OR CONTROL
CONTROL OF OF THE
THE SAID
AND EVERY
WITNESS AND EVERY SUCH RECORDS TO WHICH THE WITNESS MAY HAVE
SUCH RECORDS HAVE ACCESS PERTAINING
PERTAINING TO
DARSELL ARMSTRONG;
TINA DARSELL ARMSTRONG; DOB: 09/09/1960;
09i09/1960; at all times
any and all
at any times whatsoever.
whatsoever.
and there
Then and there t0 give evidence
to give evidence at at the
the instance of the
instance of Defendant, Do]
the Defendant, DQlgencorD
encor of of Texas Inc. d/b/a
Texas. Inc. Dollar General Store,
d/b/a Dollar Store,
represented by
represented by P.
P. Marcus White, Texas
White, Texas BarBar No. 24061263 Attorney
No. Attorney ofof Record,
Record, inin that
that Certain
Certain Cause No. DC—20-04806,
Cause No. DC-20-04806,
pending on the
pending docket ofthe
the docket District Court
of the District Court of of the l0lst Judicial
the 1015t District 0f
Judicial District of Dallas
Dallas Countv,
Countv. Texas.
Texas.
This Subpoena is
This under and
issued under
is issued by virtue
and by virtue 0f
of Rule 205.3 with the
205.3 with the above named court,
court, styled
styled
Tina Armstrong vs.
Tittu Armstrong vs. Dolgencorp 0fof Texas, Inc. d/b/a
Texas, Inc. Dollur General
d/bh, Dollar General Store
Store
’
WITNESS
m
remain from day
there remain
and there
MY HAND,
WITNESS MY tr* ?ffauv
HAI\D thisflfl’
-
or
dayof
to day
day to
NWHITESIDES
N WI.{ITESIDES
day and time t0
Public
Notary Public
Notary
to time
OJ“
until discharged
time until
time?”
WMto law.
according t0
discharged according law.
V
UV) M}
I ,,
STATE OF TEXAS NOTARY PUBLIC
PUBLIC
lD#1 26346426
lD#12634D6426
7
,h ,.
.-._ .
Contempt. Failure
P) Contempt.
=
‘
by any
Failure by without adequate
person without
any person adequate excuse to to obey aa subpoena served
served
that person
upon that person may bebe deemed aa contempt 0f of the coutt from
the court from which
which the
the subpoena lsis issued district court
or aa district
issued 0r court in
in the county in
the county in
the subpoena ls
which the is sewed, punished by
and may be punished
served, and by fine
fine or
or confinement,
confinement, or
or both
both. This
This subpoena falls
falls under exception
exception t0
to
confidentiality, Rule
confidentiality, (e) Texas rules
Rule 509 (e) rules 0f Civil Evidence.
of Civil Evidence.
OFFI CER'S RETURN
OFFICER'S
to hand
Came t0 this
this day of
day of 20- executed this
and executed the_day
this the of
day of ,
20_,
20 ,
I
in
1n
the following manner:
the following manner: By delivering
By to the
delivering t0 the witness
witness ,
a
a tlue copy
tme copy hereof,
hereof,
with attached
with attached witness
witness fee of $
fee of
Retumed this
Returned this _ of
day 0f
day ,
20
PROCESS SERVER
PROCESS
No. 68814.009
Order No.
Order 68814.009
No. DC-20-04806
Cause N0. DC-20-04806
TINA ARMSTRONG $ DISTRICT COURT
IN THE DISTRICT COURT OF
s
s
VS
vs. s
(mmmmmmfm
DALLAS COUNTY,
COUNTY, TEXAS
s
DOLGENCORP OF TEXAS, INC.
INC. s
DOLLAR GENERAL STORE
D/B/A
D/B/A $ DISTRICT
1 O1ST JUDICIAL DISTRICT
lOIST
NOTICB OF
NOTICE INTENTION FOR PRODUCTION
OF'INTENTION PRODUCTION OF DOCUMENTS
TO:
TO:ALL PARTIES BY AND THROUGH THEIR ATTORNEY(S)
ATTORNEY(S) OF
OF RECORD IN THE ATTACHED
RECORD AS PROVIDED IN ATTACHED
LIST.
SERVICE LIST.
SERVICE
will take
You will notice that
take notice that ten (10) days
ten (10) the service
after the
days after hereof, the
service hereof, the custodian ofrecords
custodian 0f for:
records for:
PARKLAND HEALTH & HOSPITAL
PARKLAND BILLING-(Billing Records)
HOSPITAL SYSTEM -- BILLING-(Billing Records)
N. STEMMONS FWY, STE 700,
8435 N. 700, DALLAS, T){75247
DALLAS, TX 75247
Shall receive
Shall receive aa Subpoena to produce
to produce documents after 09/10/2020,
documents on after or any
09/10/2020, or any other
other agreed time and/or
agreed upon time place, before
and/or place, before a
Notary Public at
Notary Public the instance
at the instance of:
of:
Written Deposition
Written Service, LLC
Deposition Service,
Whittington Place,
1755 Whittington
1755 PIace, Suite
Suite 750
Dallas, TX75234
Dallas, TX 75234
or
or its designated
its designated agent, to be used
agent, t0 in evidence
used in evidence upon the trial 0f
the trial of the
the above-styled
above-styled and
and numbered
numbered cause in the
pending in
cause pending the above
court. Notice
named court.
named is further
Notice is further given
given that
that request is hereby
request is made as
hereby made authorized under
as authorized under Rule 205.2 &
Rule 205.2 &.205.3, of
Rules 0f
205.3, Texas Rules
Civil Procedure,
Civil that the
Procedure, that the authorized officer shall
authorized officer shall issue
issue aa Duces Tecum and
Subpoena Duces cause it to
and cause to be
be served
it the witness
served on the to
witness to
produce any and
produce any and all records
all records as on the
described on
as described the attached Subpoena(s) and/or
attached Subpoena(s) Exhibit(s) and
and/or Exhibit(s) any other
and any other such
such record in the
record in the
possession, control 0f
or control
custody or
possession, custody the said
of the said witness, every such
witness, and every suchrecord to which the
record to witness
the witness pertaining t0:
access, pertaining
may have access, to:
TINA DARSELL ARMSTRONG
TINA ARMSTRONG and to turn
and to all such
turn all such records to the
over t0
records over the authorized officer so
authorized officer so that
that photographic
photographic
reproductions of
reproductions of the
the same attached.
may be made and attached.
Respectfully Submitted,
Respectfully Submitted,
/s/P.
/s/P. lyhite
Marcus White
P.
P. White
Marcus White
#: 24061263
SBA #z
Whitehurst & Cawley,
Whitehurst Cawley, LLP
Road, Suite
16300 Addison Road, Suite 100
Addison, TX 75001
Addison,
972-503-5455; Fax 972-503-6155
972-503-5455; 972-503-6t1s
mwhite@whitehurstlaw.com
mwhite@whitehurstlaw.c0m
Attorney
Attorney for: Defendant
for: Defendant
CERTIFICATE OF SERVICE
CERTIFICATE
I certify,
I certiflz, as
as authorized
authorized
agent for the
agent for the attorney of record,
attorney 0f record, P.
P. Marcus White that
Marcus White that aa true
true and
and exact
exact copy of
copy Of
foregoing Notice
foregoing of Intention
Notice 0f Intention for
for the
the Production
Production 0f
of Documents was
was served
served to all attorneys
to all of record
attorneys 0f in the
record in the
above-styled and numbered matter,
above-styled matter, said
said service being effected
service being effected in
in the following manner:
the following manner:
MAIL/RETURN RECEIPT
CERTIFIED MAIL/RETURN RECEIPT REQUESTED
REQUESTED
HAND DELIVERY
TELECOPY
OVERNIGHTA{EXT DAY DELIVERY
OVERNIGHT/NEXT DELTVERY VIA LONE STAR OR UPS
E-MAIL
W
.
.\/.._
E-FILE
:21: % a
DATED 043,50?
_
BY
SERVED TO ALL PARTIES LISTED
LISTED BELOW:
Armstrong vs.
Tina Armstrong
Tina Dolgencorp ofTexas,
vs. Dalgencorp Inc. d/b/a
of Texas, Inc. Dollar General
d/b/a Dollar General Store
Store
ATTORNEYS OF RECORD
OFRECORD
Griffin Scheumack
Griffin Scheumack
Abbott & Associates
Ben Abbott Associates
Drive
Pendleton Drive
1934 Pendleton
TX 75041
Garland, TX
Garland, '15041
972-263-5555; Fax:
972-263-5555; Fax:
Attorney For:
Attorney Plaintiff
For: Plaintiff
SUBPOENA DUCES TECUM
THE STATE OF TEXAS
County 0f
County of Dallas
Dallas
Greeting, to any
.to any Sheriff
Sheriff 0r
or Constable of the
Constable of the State of Texas
State 0f Texas.or. other.person
Greeting, authorized to
to serve
or other person authorized serve subpoenas Rule 176
subpoenas under Rule of
^1,7 6 of
Rules of
Texas Rules Civil Procedure:
of Civil Procedure: You are hereby commanded
are hereby commanded to to subpoena and summon
summon thetn" following
foffo*'ing ;rtr*(;i'-
witness(es):
D-esignated
Desi Custodian 0f
nated Custodian of Records for: for: PARKLAND
PARKLAND HEALTH
HEALTH &
& HOSPITAL
EM - BILLING
SYSTEM.
SYS
to be
to be and appear before
and Notary Public
before .aa Notary of
Public 0fdesignation for
my designation written Deposition
for Written Deposition Service, LLC, 1755
service, LLC, place,
whittington Place,
1755 Whittington
Suite 750,
Suite 750, Dallas,
Dallas,TX 75234,
TX 75234' 0n or after
on or after 09/10/2020, atthe
09/1012020, at office of
the office of the
the summoned
summoned witness.
witness. There
There to
to bring
bring and
and produce for
froduce for
inspection and
inspection photocopying ANY AND ALL BILLING RECORDS,
and photocopying RECORDS, FROM FROM 02/05/2019 To PRESENT,
02/05/2019 TO PRESENI, INCLUDING
INCLUDTNG
BUT NOT LIMITED TO, TO, PATIENT ACCOUNT INFORMATION, PAYMENT ARRANGEMENT ARRANGEMENT INFORMATION,
Preview
FILED 8/24/2020 9:50 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY No. DC-20-04806 Cause N0. DC-20-04806 Martin Reyes TINA ARMSTRONG s DISTRICT COURT OF IN THE DISTRICT $ s YS. vs. $ Cmmwiwmwom DALLAS COUNTY, COUNTY, TEXAS $ DOLGENCORP OF TEXAS, INC. INC. $ D/B/A DOLLAR GENERAL STORE D/B/A s JIJDICIAL DISTRICT 1O1ST JUDICIAL lOIST DISTRICT OF INTENTION NOTICE 0F PRODUCTION OF DOCUMENTS INTENTION FOR PRODUCTION TO: TO: ATTORNEY(S) OF ALL PARTIES BY AND THROUGH THEIR ATTORNEY(S) IN THE ATTACHED AS PROVIDED IN OF RECORD AS ATTACHED LIST. SERVICE LIST. SERVICE will take You will thatten notice that take notice (10) days ten (10) afterthe days after the service the custodian hereof, the service hereof, ofrecords custodian 0f for: records for: PARKLAND HEALTH & HOSPITAL SYSTEM—(Medical Records) SYSTEM-(Medical Records) HEALTH INFORMATION MANAGEMENT DEPARTMENT HEALTH DEPARTMENT 5201 TX75235 52OT HARRY HINES BLVD, DALLAS, TX 75235 receive aa Shall receive Shall Subpoena to to produce produce documents documents 0n after 09/10/2020, on after 09/10/2020, 0r or any any other time and/or other agreed upon time place, before and/or place, before a Public at Notary Public Notary the instance at the of: instance of: Written Deposition Written Service, LLC Deposition Service, Whittington Place, 1755 Whittington Place, Suite Suite 750 . Dallas, TX Dallas, TX75234 75234 or its or its designated to be agent, t0 designated agent, in evidence be used in evidence upon the trial 0f the trial of the the above-styled above-styled and numbered cause pending in the pending in the above namedcourt. named court. Notice is further given that request is hereby made as authorized under Rule 205.2 & 205.3, Texas Rules of NoticeisfurthergiventhatrequestisherebymadeasauthorizedrmderRule205.2&.205.3,TexasRulesof Civil Procedure, Civil Procedure, that that the the officer shall authorized officer authorized issue aa Subpoena Duces shall issue Duces Tecum and and cause it to cause it to be be served the witness served on the to witness to produce any and produce any and all records all records as described on as described the attached on the attached Subpoena(s) Subpoena(s) and/or Exhibit(s) and and/or Exhibit(s) any other and any other such record in the record in the possession, custody possession, or control custody or control of of the the said witness, and every said witness, record t0 every such record to which the the witness witness may have access, pertaining t0: access, pertaining to: TINA DARSELL ARMSTRONG TINA ARMSTRONG and to turn and t0 all such turn all records over such records to the over to the authorized officer sb authorized officer so that that photographic photographic of the reproductions of reproductions attached. the same may be made and attached. Respectfu lly Submitted, Respectfully Submitted, /s/P. /s/P. Murcus White Marcus White P. P. White Marcus White #: 24061263 SBA #: Whitehurst & Cawley, Whitehurst Cawley, LLP Addison Road, 16300 Addison Road, Suite Suite 100 Addison, TX 75001 Addison, 972-503-5455; Fax 972—503-6155 972-503-5455; 912-503-6155 mwhite@whitehurstlaw.com mwhite@whitehurstlaw.c0m Attorney Attorney for: Defendant for: CERTIFICATE OF SERVICE CERTIFICATE I certify, I certi$r, as as authorized authorized agent for the agent for the attorney of record, attorney 0f P. Marcus record, P. White that Marcus White that aa true true and of copy 0f exact copy and exact foregoing Notice foregoing of Intention Notice of for the Intention for the Production of Production 0fDocuments was was served to all served to all attorneys of record attorneys of in the record in the above-styled and numbered above-styled matter, said numbered matter, said service being effected service being effected in in the following manner: the following manner: MAIL/RETURN RECEIPT REQUESTED CERTIFIED MAIL/RETURN REQUESTED }IAND DELIVERY HAND TELECOPY OVERNIGHTA{EXT DAY DELIVERY OVERNIGHT/NEXT DELTVERY VIA LONE STAR OR UPS E-MAIL E-FILE DATED: BY SERVED TO ALL PARTIES LISTED SERVED LISTED BELOW: Armstrongvs. Tina Armstrong Tina Dolgencorp ofTexas, vs. Dolgencorp Inc. d/b/a of Texas, Inc. Dollar General d/b/a Dollar General Store Store ATTORNEYS OF RECORD OFRECORD Grifhn Scheumack Griffin Abbott & Associates Ben Abbott Associates Drive Pendleton Drive 1934 Pendleton Garland, TX 75041 Garland, TX 75041 9'72-263-5555; Fax: 972-263-5555; Fax: Attorney For: Attorney Plaintiff For: Plaintiff SUBPOENA DUCES TECUM THE STATE OF TEXAS County 0f County of Dallas Dallas Greeting, 1o Greeting, to any Sheriff or any Sheriff or Constable of the Constable of the State of Texas State 0f Texas or_ other person or other person authorized authorized to to serve of Rule 1766 0f serve subpoenas under Rule lj Texas Rules 0f Civil Procedure: of Civil Procedure: You are hereby commanded are hereby commanded t0 to subpoena and summon summon the following witness(es): the following witness(es): Designated Custodian 0f nated Custodian of Records for: PARKLAND for: & HEALTH & PARKLAND HEALTH HOSPITAL SYSTEM ls)‘e{ssi to be t0 before aaNotary and appear before be and Notary Public of Public of designation for my designation Written Deposition for Written Deposition Service, LLC, 1755 Service, LLC, Whittington Place, lTSS Whittington Place, Suite 750, Suite Dallas, 750, Dallas, TX TX '75234, 0n 75234, or on or after after 09/10/2020, at the 0911012020, at office 0f the office of the the summoned summoned witness. witness. There to bring There to bring and produce for produce for inspection and inspection ANY and photocopying ALL MEDICAL RECORDS (EXCLUDING BILLING RECORDS), FROM ANY AND ALL photocopying 2I5I2OI4 2/5/2014TO PRESENT, TO PRESENT, INCLUDING BUT NOT INCLUDING BUT LIMITED TO NOT LIMITED TO RECORDS RECORDS REGARDING THE PATIENT'S REGARDING THE CONDITIONS AND TREATMENTS, CONDITIONS TREATMENTS, DOCTOR'S NOTES, EVALUATIONS, OFFICE NOTES, PROGRESS NOTES, AUDIT REPORTS, AUDIT REPORTS, CORRESPONDENCE WITH OTHER CORRESPONDENCE WITH OTHER PHYSICIANS, PHYSICIANS, THERAPISTS, HOSPITALS HOSPITALS AND/OR AND/OR HEALTHCARE PROVIDERS, PHYSICAL THERAPY RECORDS, RECORDS, LAB REPORTS, RADIOLOGY REPORTS, ALL OTHER DIAGNOSTIC DIAGNOSTIC REPORTS, PRESCRIPTIONS, PRESCRIPTIONS, REFERRALS T0 TO OTHER HEALTH CARE PROVIDERS, PROVIDERS, CLAIMS, WORKER'S CLAIMS, WORKER'S COMPENSATION COMPENSATION RECORDS, HOSPITAL RECORDS, RECORDS, HOSPITAL RECORDS, THERAPISTS' THERAPISTS' RECORDS, PATIENT INFORMATION PATIENT INFORMATION FORMS, PATIENT INSURANCE FORMS, PATIENT INSURANCE FORMS, FORMS, INTAKE FORMS, FORMS, LITIGATION FILES, FILES, HANDWRITTEN NOTES, LETTERS OF PROTECTION, PROTECTION, TELEPHONE TELEPHONE MESSAGES, MESSAGES, NURSES' NURSES'NOTES, NOTES, EVERY SUCH RECORD, LIMITED TO, RBCORD, INCLUDING BUT NOT LIMITED TO, THOSE THOSE EXISTING IN IN ELECTRONIC 0ROR MAGNETIC FORM, INCLUDING FORM, CORRESPONDENCE IN THE POSSESSION, CUSTODY INCLUDING CORRESPONDENCE IN THE CUSTODY OR OR CONTROL CONTROL OF OF THE THE SAID AND EVERY WITNESS AND EVERY SUCH RECORDS TO WHICH THE WITNESS MAY HAVE SUCH RECORDS HAVE ACCESS PERTAINING PERTAINING TO DARSELL ARMSTRONG; TINA DARSELL ARMSTRONG; DOB: 09/09/1960; 09i09/1960; at all times any and all at any times whatsoever. whatsoever. and there Then and there t0 give evidence to give evidence at at the the instance of the instance of Defendant, Do] the Defendant, DQlgencorD encor of of Texas Inc. d/b/a Texas. Inc. Dollar General Store, d/b/a Dollar Store, represented by represented by P. P. Marcus White, Texas White, Texas BarBar No. 24061263 Attorney No. Attorney ofof Record, Record, inin that that Certain Certain Cause No. DC—20-04806, Cause No. DC-20-04806, pending on the pending docket ofthe the docket District Court of the District Court of of the l0lst Judicial the 1015t District 0f Judicial District of Dallas Dallas Countv, Countv. Texas. Texas. This Subpoena is This under and issued under is issued by virtue and by virtue 0f of Rule 205.3 with the 205.3 with the above named court, court, styled styled Tina Armstrong vs. Tittu Armstrong vs. Dolgencorp 0fof Texas, Inc. d/b/a Texas, Inc. Dollur General d/bh, Dollar General Store Store ’ WITNESS m remain from day there remain and there MY HAND, WITNESS MY tr* ?ffauv HAI\D thisflfl’ - or dayof to day day to NWHITESIDES N WI.{ITESIDES day and time t0 Public Notary Public Notary to time OJ“ until discharged time until time?” WMto law. according t0 discharged according law. V UV) M} I ,, STATE OF TEXAS NOTARY PUBLIC PUBLIC lD#1 26346426 lD#12634D6426 7 ,h ,. .-._ . Contempt. Failure P) Contempt. = ‘ by any Failure by without adequate person without any person adequate excuse to to obey aa subpoena served served that person upon that person may bebe deemed aa contempt 0f of the coutt from the court from which which the the subpoena lsis issued district court or aa district issued 0r court in in the county in the county in the subpoena ls which the is sewed, punished by and may be punished served, and by fine fine or or confinement, confinement, or or both both. This This subpoena falls falls under exception exception t0 to confidentiality, Rule confidentiality, (e) Texas rules Rule 509 (e) rules 0f Civil Evidence. of Civil Evidence. OFFI CER'S RETURN OFFICER'S to hand Came t0 this this day of day of 20- executed this and executed the_day this the of day of , 20_, 20 , I in 1n the following manner: the following manner: By delivering By to the delivering t0 the witness witness , a a tlue copy tme copy hereof, hereof, with attached with attached witness witness fee of $ fee of Retumed this Returned this _ of day 0f day , 20 PROCESS SERVER PROCESS No. 68814.009 Order No. Order 68814.009 No. DC-20-04806 Cause N0. DC-20-04806 TINA ARMSTRONG $ DISTRICT COURT IN THE DISTRICT COURT OF s s VS vs. s (mmmmmmfm DALLAS COUNTY, COUNTY, TEXAS s DOLGENCORP OF TEXAS, INC. INC. s DOLLAR GENERAL STORE D/B/A D/B/A $ DISTRICT 1 O1ST JUDICIAL DISTRICT lOIST NOTICB OF NOTICE INTENTION FOR PRODUCTION OF'INTENTION PRODUCTION OF DOCUMENTS TO: TO:ALL PARTIES BY AND THROUGH THEIR ATTORNEY(S) ATTORNEY(S) OF OF RECORD IN THE ATTACHED RECORD AS PROVIDED IN ATTACHED LIST. SERVICE LIST. SERVICE will take You will notice that take notice that ten (10) days ten (10) the service after the days after hereof, the service hereof, the custodian ofrecords custodian 0f for: records for: PARKLAND HEALTH & HOSPITAL PARKLAND BILLING-(Billing Records) HOSPITAL SYSTEM -- BILLING-(Billing Records) N. STEMMONS FWY, STE 700, 8435 N. 700, DALLAS, T){75247 DALLAS, TX 75247 Shall receive Shall receive aa Subpoena to produce to produce documents after 09/10/2020, documents on after or any 09/10/2020, or any other other agreed time and/or agreed upon time place, before and/or place, before a Notary Public at Notary Public the instance at the instance of: of: Written Deposition Written Service, LLC Deposition Service, Whittington Place, 1755 Whittington 1755 PIace, Suite Suite 750 Dallas, TX75234 Dallas, TX 75234 or or its designated its designated agent, to be used agent, t0 in evidence used in evidence upon the trial 0f the trial of the the above-styled above-styled and and numbered numbered cause in the pending in cause pending the above court. Notice named court. named is further Notice is further given given that that request is hereby request is made as hereby made authorized under as authorized under Rule 205.2 & Rule 205.2 &.205.3, of Rules 0f 205.3, Texas Rules Civil Procedure, Civil that the Procedure, that the authorized officer shall authorized officer shall issue issue aa Duces Tecum and Subpoena Duces cause it to and cause to be be served it the witness served on the to witness to produce any and produce any and all records all records as on the described on as described the attached Subpoena(s) and/or attached Subpoena(s) Exhibit(s) and and/or Exhibit(s) any other and any other such such record in the record in the possession, control 0f or control custody or possession, custody the said of the said witness, every such witness, and every suchrecord to which the record to witness the witness pertaining t0: access, pertaining may have access, to: TINA DARSELL ARMSTRONG TINA ARMSTRONG and to turn and to all such turn all such records to the over t0 records over the authorized officer so authorized officer so that that photographic photographic reproductions of reproductions of the the same attached. may be made and attached. Respectfully Submitted, Respectfully Submitted, /s/P. /s/P. lyhite Marcus White P. P. White Marcus White #: 24061263 SBA #z Whitehurst & Cawley, Whitehurst Cawley, LLP Road, Suite 16300 Addison Road, Suite 100 Addison, TX 75001 Addison, 972-503-5455; Fax 972-503-6155 972-503-5455; 972-503-6t1s mwhite@whitehurstlaw.com mwhite@whitehurstlaw.c0m Attorney Attorney for: Defendant for: Defendant CERTIFICATE OF SERVICE CERTIFICATE I certify, I certiflz, as as authorized authorized agent for the agent for the attorney of record, attorney 0f record, P. P. Marcus White that Marcus White that aa true true and and exact exact copy of copy Of foregoing Notice foregoing of Intention Notice 0f Intention for for the the Production Production 0f of Documents was was served served to all attorneys to all of record attorneys 0f in the record in the above-styled and numbered matter, above-styled matter, said said service being effected service being effected in in the following manner: the following manner: MAIL/RETURN RECEIPT CERTIFIED MAIL/RETURN RECEIPT REQUESTED REQUESTED HAND DELIVERY TELECOPY OVERNIGHTA{EXT DAY DELIVERY OVERNIGHT/NEXT DELTVERY VIA LONE STAR OR UPS E-MAIL W . .\/.._ E-FILE :21: % a DATED 043,50? _ BY SERVED TO ALL PARTIES LISTED LISTED BELOW: Armstrong vs. Tina Armstrong Tina Dolgencorp ofTexas, vs. Dalgencorp Inc. d/b/a of Texas, Inc. Dollar General d/b/a Dollar General Store Store ATTORNEYS OF RECORD OFRECORD Griffin Scheumack Griffin Scheumack Abbott & Associates Ben Abbott Associates Drive Pendleton Drive 1934 Pendleton TX 75041 Garland, TX Garland, '15041 972-263-5555; Fax: 972-263-5555; Fax: Attorney For: Attorney Plaintiff For: Plaintiff SUBPOENA DUCES TECUM THE STATE OF TEXAS County 0f County of Dallas Dallas Greeting, to any .to any Sheriff Sheriff 0r or Constable of the Constable of the State of Texas State 0f Texas.or. other.person Greeting, authorized to to serve or other person authorized serve subpoenas Rule 176 subpoenas under Rule of ^1,7 6 of Rules of Texas Rules Civil Procedure: of Civil Procedure: You are hereby commanded are hereby commanded to to subpoena and summon summon thetn" following foffo*'ing ;rtr*(;i'- witness(es): D-esignated Desi Custodian 0f nated Custodian of Records for: for: PARKLAND PARKLAND HEALTH HEALTH & & HOSPITAL EM - BILLING SYSTEM. SYS to be to be and appear before and Notary Public before .aa Notary of Public 0fdesignation for my designation written Deposition for Written Deposition Service, LLC, 1755 service, LLC, place, whittington Place, 1755 Whittington Suite 750, Suite 750, Dallas, Dallas,TX 75234, TX 75234' 0n or after on or after 09/10/2020, atthe 09/1012020, at office of the office of the the summoned summoned witness. witness. There There to to bring bring and and produce for froduce for inspection and inspection photocopying ANY AND ALL BILLING RECORDS, and photocopying RECORDS, FROM FROM 02/05/2019 To PRESENT, 02/05/2019 TO PRESENI, INCLUDING INCLUDTNG BUT NOT LIMITED TO, TO, PATIENT ACCOUNT INFORMATION, PAYMENT ARRANGEMENT ARRANGEMENT INFORMATION,