Preview
FILED
4/6/2020 2:32 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Veronica Vaughn DEPUTY
CAUSE NO. DC-19-06151
DALLAS COUNTY HOSPITAL IN THE DISTRICT COURT
DISTRICT d/b/a PARKLAND HEALTH
& HOSPITAL SYSTEM,
Plaintiff,
V. DALLAS COUNTY, TEXAS
CHEROKEE INSURANCE COMPANY
and COMERICA BANK
Defendants. 193m JUDICIAL DISTRICT
PLAINTIFF DALLASCOUNTY HOSPITAL DISTRICT
D/B/A PARKLAND HEALTH & HOSPITAL SYSTEM’S
DESIGNATION OF EXPERT WITNESSES
Plaintiff Dallas County Hospital District d/b/a Parkland Health & Hospital System,
pursuant t0 Texas Rule 0f Civil Procedure 194.2(f), submits the following Designation of Expert
Witnesses:
1. Douglas Turek
c/o The Turek Law Firm, PC
9595 Six Pines Drive, Suite 8210
The Woodlands, Texas 77380
28 1 -296-6920
If necessary, Mr. Turek Will testify as t0 the attorney’s fees and litigation expenses
incurred by Plaintiff as a result of this suit. A copy of Mr. Turek’s current resume is
attached hereto as Exhibit A.
Due ongoing nature 0f this matter, a complete description of Mr. Turek’s opinions
t0 the
cannot be provided as 0f the date of these Disclosures. However, Mr. Turek Will testify
thatThe Turek Law Firm, PC has contracted With Parkland for a contingency fee 0f
twenty-five percent (25%) 0f any recovery. Mr. Turek Will testify that, as 0f the date of
these Disclosures, counsel for Parkland has expended approximately 55.2 hours 0n this
matter. A summary 0f hours 0f work performed is attached hereto as Exhibit B. As the
case is in active litigation, the numbers of hours and the expenses will increase and will
be subject t0 supplementation.
Further, Mr. Turek will testify that he is familiar With the rates customarily charged in
Dallas County for similar legal services and that the typical hourly rate charged for Mr.
Turek’s services $350.00; that typical the hourly rate for Erin Hartung’s services is
is
$250.00; that the typical hourly rate for Emily Marr’s services is $250.00; that the typical
hourly rate for Amy Kogan’s services is $150.00; and that the typical hourly rate for
McCulloch’s services is $75.00. Mr. Turek will
Patricia testify as t0 the nature and
amount 0f work performed in this matter.
Mr. Turek’s opinion that the number 0f hours expended by The Turek Law Firm
It is
representing Parkland in this matter and the hourly rates for each attorney that has
performed work in this matter are reasonable considering the rates customarily Charged in
Dallas County for similar legal services. It is also Mr. Turek’s opinion that When the
number 0f hours expended are multiplied times the reasonable and typical hourly rates 0f
the attorneys that have performed work in this matter the current reasonable and incurred
attorney’s fees for Parkland’s prosecution of this matter as 0f the date 0f these
Disclosures are $12,325.00.
Lastly, Mr. Turek Will testify that The Turek Law Firm, PC has had a professional
relationship With Parkland for at least fourteen (14) years.
Mr. Turek will rely on the contract executed between The Turek Law Firm, PC and
Parkland, as well as billing records to support his opinions. A redacted copy 0f the
Agreement between Parkland and The Turek Law Firm is attached as Exhibit C.
Mr. Turek will also testify that Parkland has incurred $625.05 in expenses for the
prosecution 0f this matter. A Summary 0f the expenses incurred in the prosecution 0f
this matter is attached hereto as Exhibit D. It is Mr. Turek’s opinion that these incurred
expenses are reasonable and were necessary for the prosecution of this matter.
Plaintiff Dallas County Hospital District d/b/a Parkland Health and Hospital System
reserves the right t0 supplement this list in accordance with the Texas Rules 0f Civil
Procedure.
Respectfully submitted,
THE TUREK LAW FIRM, PC
By: /s/Douglas Turek
Douglas Turek
State Bar No. 00792882
dturek@tureklawfirm.com
Erin Hartung
ehartung@tureklawfirm.com
State Bar N0. 24090237
Emily Marr
State Bar N0. 24102595
emarr@tureklawfirm.com
9595 Six Pines Drive, Suite 8210
The Woodlands, Texas 77380
Tel.: (281) 296-6920
Fax: (281) 296-0733
ATTORNEYS FOR PLAINTIFF DALLAS
COUNTY HOSPITAL DISTRICT D/B/A
PARKLAND HEALTH AND HOSPITAL
SYSTEM
CERTIFICATE OF SERVICE
hereby certify that a true and correct copy 0f the above was served 0n each attorney of
I
record 0r party in accordance With the Texas Rules 0f Civil Procedure on this 6th day 0f April,
2020.
P. Marcus White
WHITEHURST & CAWLEY, LLP
16300 Addison Road, Suite 100
Addison, Texas 75001
Via Electronic Service
/s/Douglas Turek
Douglas Turek
DTzEH/pam
Https://tureklawfirm.sharepoint.com/Shared Documents/TLF Operations/CLIENTS/HOSPITAL LITIGATION/PARKLAND.1032.00/GAYTAN.1032.139/XEXPERT WITNESS_LIST
(Gaytan).00 1 .docx
March 30, 2020
EXHIBIT A
THE TUREK LAW FIRM PC
DOUGLAS D. TUREK
9595 Six Pines Drive, Suite 8210
The Woodlands, Texas 773 82
(28 1) 296-6920
dturek@tureklawfirm.com
EMPLOYMENT: THE TUREK LAW FIRM, PC
Founding Shareholder (June 2001 t0 present)
MEDDATA, INC.
Sr. VP of Regulatory and Governmental Affairs
(September 2015 to present)
Formerly Alegis Revenue Group, LLC
Chief Operating Officer (May 2008 t0 September 2015)
CARDON HEALTHCARE NETWORK, INC.
Chief Operating Officer (June 2001 — March 2008)
GLICKMAN & HUGHES, LLP
Associate Attorney (March 1995 - June 2001)
Law Clerk (May 1994 -
February 1995)
164th DISTRICT COURT - JUDGE KATIE KENNEDY
Judicial Internship (March - August 1993, February - May 1994)
EDUCATION: NATIONAL INSTITUTE OF TRIAL ADVOCACY
National Session (Boulder, Colorado) -
July, 1999
UNIVERSITY OF HOUSTON LAW CENTER
Juris Doctorate - December, 1994
Houston Journal oflnternational Law, Research Editor
Phi Delta Phi Honors Fraternity
UNIVERSITY OF TEXAS AT AUSTIN
Bachelor of Arts, History - December, 1991
MEMBERSHIPS: Texas State Bar
Utah State Bar
California State Bar
Oklahoma State Bar
Nevada State Bar
Pennsylvania State Bar
Missouri State Bar
Kansas State Bar
Tennessee State Bar
Florida State Bar
Management Association (2001 - present)
Healthcare Financial
American College of Healthcare Executives (2010 — present)
American Association 0f Healthcare Administrative Management (2018 —
present)
EXHIBIT B
THE TUREK LAW FIRM PC
TIMESHEET
THE TUREK LAW FIRM pc
Dale Hours UTBMS task code
(ABA) Communicate (other outside cuunsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Phone call with Marcus
Plan and prepare for L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Review communication from
Plan and prepare for L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
(ABA! Communicate (other outside counsel) L110 Fact
L110 Fact Review matter draft letter to TPL verification of check
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and phone call with o/c re: status of checking Tn with insurance company,-
and Administration with via e-mail
Communicate (other outside counse‘) L160 Settlement/Non-Einding
L160 ADR E-mail to
Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Review matter draft demand letter to
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Revise demand letter
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
enclosure for dema nd letter
Communicate L110 Fact L110 Fact
Draf‘t/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Review/analyze L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and :review check received; phone
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Follow with
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Review matter with
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Phone call with review Comerica website re: affidavit of
Review communication
Revise affidavit of
Communicate L120 L120
Review affidavit tn client
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Follow with re: indemnification in affidavit of
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Review case for send ermail to counse‘ on matter
Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Review matter draft contact letter
Plan and for L210 L210
L210
Research C200
L210 L210
L210 L210 Review revise PO P
Research L210 L210
Research L210 L210
Communicate L120 L120
Communicate L210 L210
Research L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
exas SOS website research
Communicate (with client) L190 Other Case Assessment, L190 Other Case Assessment, Development and
and Administration
Communicate (with client) L190 Other Case Assessment, L190 Other Case Assessment, Development and
and Administration
L210 L210
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
demand exhibits
L210 L210 Review for SOL details
L210 L210
TIMESHEET
THE TUREK LAW FIRM pc
Communicate
L210
Communicate Erin
L210 POP Exhibit A Erin
Communicate Erin
Communicate L210 Erin
L210 L210 to court Patricia McCulloch
L210 Review citation revise letter to court Erin
L210 L210 RFD Patricia McCulloch
L210 L210 notice of of address Patricia McCulloch
L310 Written I310 Written Review matter and revise draft RFD Erin
L310 Written L310 Written to Comerica RFDs Turek
L310 Written L3 10 Written Revise RFD instructions for of docs Erin
for L140 L140 all dates contained on order Patricia McCulloch
Review correspondence from Camerica atty; Review file, emails, and RFPs, voicemail m any; email
L320 Document Production L320 Document Production and send Rule 11 Erin
Plan and for L320 Document Production L320 Document Production Review D Comerica RFP' search emails for Erin
L210 L210 RFP Patricia McCulloch
Revise RFP responses; review production documents far redaction and privilege application; add'l due diligence
L320 Document Production I320 Document Production for documents Erin
L320 Document Production L320 Document Production Erin
L320 Document Production L320 Document Production Erin
L310 Written L3 10 Written Tu rek
L320 Document Production L320 Document Production Erin
L320 Document Production L320 Document Production Patricia McCulloch
L320 Document Production L320 Document Production Final review 0f documents for redaction materials Erin
L210 L210 draft lst Amended Petition Erin
Research C200 Law Law Erin
L140 L140 . Patricia McCulloch
Communicate L120 L120 Patricia McCulloch
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration to re mediator Erin
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Review from re mediator draft letter to court Erin
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Letter lo Court Re Mediator
L310 Written L310 Written Draft RFP INT to Cherokee and Comerica
L310 Written L310 Written
L310 Written L310 Written m Comerica
Research P270 Reviews P270 Reviews
Communicate P300 P300
Research P270 Reviews P270 Reviews
Communicate P300 F300
Research P270 Reviews P270 Reviews
Communicate P300 P300
Research C200 Law
L210 L210
L310 Written L3 10 Written Review
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration with Marcus continuance
L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Draft Mtn for order
L240 Motions L240 Motions Draft draft affidavits
L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Motion for T Continence
L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Mtn for Continuance finalized and sent to
Communicate L160 ADR L160 ADR
Communicate (other outside counse‘) L160 Settlement/Non—Binding
L160 ADR to Cherokee Erin
L140 L140 reviewed Patricia McCulloch
L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Draft order calculate dates Erin
TIMESHEET
THE TUREK LAW FIRM PC
Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Draf‘t/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and
Revise
Communicate L120 L120
Research P270 Reviews P270 Reviews
Research P270 Reviews P270 Reviews
(ABA! Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration on USO Erin
L440 Other Trial and L440 Other Trial and Review and deadhnes on lit calendar Patricia McCulloch
L440 Other Trial and L440 Other Trial and Reviewed local ru‘es for deadlines. Patricia McCulloch
L210 L210 Erin
Research L240 Motions L240 Motions Erin
Communicate (other outside counse‘) L160 Settlemenl/Non-Binding
L160 with Erin
Communicate L160 ADR L160 with Erin
L240 Motions L240 Mnflons review Erin
L240 Motions L240 Motions Nunsuit for Comerica
Communicate (other outside counse‘) L160 Settlement/Non-Binding
L160 ADR Follow email to Erin
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration Follow to Comerica re MSJ Erin
L210 L210 finalize lst Am Pet for Erin
L160 ADR L160 ADR Draft Rule 11 dismissal Comerica Erin
L160 ADR L160 ADR and send Rule 11 to Comerica Erin
Communicate L160 ADR L160 ADR Erin
(ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and
and Administration to Comerica re MSJ removal Erin
L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions revise exhibits Erin
L140 L140 timesheet Patricia McCulloch
Total Hours 6
EXHIBIT C
THE TUREK LAW FIRM PC
TUREK DEVORE, PC JESSICA D. GUOBAIMA‘:
RUSS DEVOREak 25227 Grogans Mill Road, Suite 100A
J_ ERIN LOWINSHE"
Junm E MYERQW The Woodlands, Texas 77330 ASSOCIATES
Telephone: (281) 296—6920
DOUGLAS D TURFK+' ’
Facsimile: (281) 296-0733 PATRICIA MCCULLOCH
www.turekdevore.c0n1 LISA SCOGGINS
LEGAL :KSSIsl'AN'rS
May 29, 2014
Paul Leslie
General Counsel
Attention: Brenda Neel Hight
Parkland Health & Hospital System
520] Harry Hines Boulevard
Dallas, Texas 75235
Re: Retention Agreement between
Parkland Health & Hospital System and Turek DeVore, PC
Dear Ms. Hight:
Pursuant t0 our recent conversations, Parkland Health 3c Hospital System (“Parkland”)
has decided t0 continue t0 retain Turek DeVore, PC (“TDV”) to represent Parkland in a variety
of matters, inciuding, but not limited to General Litigation and Account Collections. Parkland
and TDV agree that this letter will serve a5 the agraement that controls TDV’s representation of
Parkland.
I. GENERAL LITIGATION
Parkland has decided to retain Turek DeVore, PC (“TDV”) to pursue and de fend non-
account legal claims, as the need arises (“Representation”).
'
Licensed in Calilbrnla, Kansas. Missouri, Nm'ada, Oklahoma, Punm‘yh'ania. Tennuesste. Texas. and Utah
"'
Licensed in Cnlurudu, New Mexico. Oklahoma, and 'l‘exas
'Liitensed in Culif'urnia :Ind Texas
“Licensed in Illinois 3nd Texas
~ Licensed in Texas
B. Fees and Expenses
1. Contingency Fees and Expenses
For matters
in which Parkland is seeking a recovery from a third party, Parkland agrees
that it pay TDV twenty-two and one-half percent (22.5%) ofall recovered funds prior t0 suit
will
being filed by any party and twenty—five percent (25%) of all recovered funds afier suit is filed
by either Parkland 0r a Third-Party.
In these matters,TDV will absorb the expenses 0f litigation, except in cases in which
Turek notifies Parkland TDV reasonably believes expenses exceed a reasonable amount if
that
Parkland seeks to continue litigation. In such matters Parkiand will reimburse TDV expenses
upon appropriate documentation. Additionally, in cases in which it becomes apparent that
Parkland may be any alleged wrongdoing, TDV agrees to timely advise Parkland of
liable for
such potential exposure. Parkland remains responsible for any amounts adjudged against or
otherwise agreed to be paid by Parkland.
2. Hourlv Fees and Expenses
For referrals to TDV t0 defend Parkland or in which Parkland is not seeking affirmative
monetary relief, Parkland agrees to pay TDV the following hourly rates:
Hourly Rate Discounted Rate
Douglas Turek $ 350.00fhour $ 250.00fh0ur
Jessica Guobadia $ 250.00fhour $ 175.00fh0ur
Erin Lowinske $ 150.00fhour $ 125.00fh0ur
Legal Assistants $ 75.00fl10ur $ 50.00fh0ur
Parkland will be responsible for any expenses incurred in which TDV is retained t0
defend Parkland 0n an hourly basis. TDV will review expenses with Parkland: including
discovery expenses, prior to incurring such expenses. [n cases in which it becomes apparant that
Parkland may be any alieged wrongdoing, Parkland remains responsible for any
liable for
amounts adjudged against or otherwise agreed t0 be paid by Parkland.
Iv. WI:
This letter and the Parkland Counsel Guidelines constitute the entire terms 0f the
engagement 0f TDV in the Representation. These written terms of engagement are not subject to
any oral agreements or understandings, and they can ha modified only by further mitten
agreement signed both by Parkland and TDV.
If this letter accurately reflects the agreement between Parkiand and TDV, please sign in
the: space provided below and send the signed letter back to our office. By signing baiow, you
acknowledga that you have thc authority to bind Parkland to this agreement. If you have any
questions or revisions, please call me 0r Jessica Guobadia at (231) 296-6920.
We look forward t_o working with Parkland 0n these matters. It is our hope that cantinuing this
relationship results in future. success for Parkland. As always, thank yau for the opportunity.
Do glas D. Turek
dturek@turel
Preview
FILED 4/6/2020 2:32 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Veronica Vaughn DEPUTY CAUSE NO. DC-19-06151 DALLAS COUNTY HOSPITAL IN THE DISTRICT COURT DISTRICT d/b/a PARKLAND HEALTH & HOSPITAL SYSTEM, Plaintiff, V. DALLAS COUNTY, TEXAS CHEROKEE INSURANCE COMPANY and COMERICA BANK Defendants. 193m JUDICIAL DISTRICT PLAINTIFF DALLASCOUNTY HOSPITAL DISTRICT D/B/A PARKLAND HEALTH & HOSPITAL SYSTEM’S DESIGNATION OF EXPERT WITNESSES Plaintiff Dallas County Hospital District d/b/a Parkland Health & Hospital System, pursuant t0 Texas Rule 0f Civil Procedure 194.2(f), submits the following Designation of Expert Witnesses: 1. Douglas Turek c/o The Turek Law Firm, PC 9595 Six Pines Drive, Suite 8210 The Woodlands, Texas 77380 28 1 -296-6920 If necessary, Mr. Turek Will testify as t0 the attorney’s fees and litigation expenses incurred by Plaintiff as a result of this suit. A copy of Mr. Turek’s current resume is attached hereto as Exhibit A. Due ongoing nature 0f this matter, a complete description of Mr. Turek’s opinions t0 the cannot be provided as 0f the date of these Disclosures. However, Mr. Turek Will testify thatThe Turek Law Firm, PC has contracted With Parkland for a contingency fee 0f twenty-five percent (25%) 0f any recovery. Mr. Turek Will testify that, as 0f the date of these Disclosures, counsel for Parkland has expended approximately 55.2 hours 0n this matter. A summary 0f hours 0f work performed is attached hereto as Exhibit B. As the case is in active litigation, the numbers of hours and the expenses will increase and will be subject t0 supplementation. Further, Mr. Turek will testify that he is familiar With the rates customarily charged in Dallas County for similar legal services and that the typical hourly rate charged for Mr. Turek’s services $350.00; that typical the hourly rate for Erin Hartung’s services is is $250.00; that the typical hourly rate for Emily Marr’s services is $250.00; that the typical hourly rate for Amy Kogan’s services is $150.00; and that the typical hourly rate for McCulloch’s services is $75.00. Mr. Turek will Patricia testify as t0 the nature and amount 0f work performed in this matter. Mr. Turek’s opinion that the number 0f hours expended by The Turek Law Firm It is representing Parkland in this matter and the hourly rates for each attorney that has performed work in this matter are reasonable considering the rates customarily Charged in Dallas County for similar legal services. It is also Mr. Turek’s opinion that When the number 0f hours expended are multiplied times the reasonable and typical hourly rates 0f the attorneys that have performed work in this matter the current reasonable and incurred attorney’s fees for Parkland’s prosecution of this matter as 0f the date 0f these Disclosures are $12,325.00. Lastly, Mr. Turek Will testify that The Turek Law Firm, PC has had a professional relationship With Parkland for at least fourteen (14) years. Mr. Turek will rely on the contract executed between The Turek Law Firm, PC and Parkland, as well as billing records to support his opinions. A redacted copy 0f the Agreement between Parkland and The Turek Law Firm is attached as Exhibit C. Mr. Turek will also testify that Parkland has incurred $625.05 in expenses for the prosecution 0f this matter. A Summary 0f the expenses incurred in the prosecution 0f this matter is attached hereto as Exhibit D. It is Mr. Turek’s opinion that these incurred expenses are reasonable and were necessary for the prosecution of this matter. Plaintiff Dallas County Hospital District d/b/a Parkland Health and Hospital System reserves the right t0 supplement this list in accordance with the Texas Rules 0f Civil Procedure. Respectfully submitted, THE TUREK LAW FIRM, PC By: /s/Douglas Turek Douglas Turek State Bar No. 00792882 dturek@tureklawfirm.com Erin Hartung ehartung@tureklawfirm.com State Bar N0. 24090237 Emily Marr State Bar N0. 24102595 emarr@tureklawfirm.com 9595 Six Pines Drive, Suite 8210 The Woodlands, Texas 77380 Tel.: (281) 296-6920 Fax: (281) 296-0733 ATTORNEYS FOR PLAINTIFF DALLAS COUNTY HOSPITAL DISTRICT D/B/A PARKLAND HEALTH AND HOSPITAL SYSTEM CERTIFICATE OF SERVICE hereby certify that a true and correct copy 0f the above was served 0n each attorney of I record 0r party in accordance With the Texas Rules 0f Civil Procedure on this 6th day 0f April, 2020. P. Marcus White WHITEHURST & CAWLEY, LLP 16300 Addison Road, Suite 100 Addison, Texas 75001 Via Electronic Service /s/Douglas Turek Douglas Turek DTzEH/pam Https://tureklawfirm.sharepoint.com/Shared Documents/TLF Operations/CLIENTS/HOSPITAL LITIGATION/PARKLAND.1032.00/GAYTAN.1032.139/XEXPERT WITNESS_LIST (Gaytan).00 1 .docx March 30, 2020 EXHIBIT A THE TUREK LAW FIRM PC DOUGLAS D. TUREK 9595 Six Pines Drive, Suite 8210 The Woodlands, Texas 773 82 (28 1) 296-6920 dturek@tureklawfirm.com EMPLOYMENT: THE TUREK LAW FIRM, PC Founding Shareholder (June 2001 t0 present) MEDDATA, INC. Sr. VP of Regulatory and Governmental Affairs (September 2015 to present) Formerly Alegis Revenue Group, LLC Chief Operating Officer (May 2008 t0 September 2015) CARDON HEALTHCARE NETWORK, INC. Chief Operating Officer (June 2001 — March 2008) GLICKMAN & HUGHES, LLP Associate Attorney (March 1995 - June 2001) Law Clerk (May 1994 - February 1995) 164th DISTRICT COURT - JUDGE KATIE KENNEDY Judicial Internship (March - August 1993, February - May 1994) EDUCATION: NATIONAL INSTITUTE OF TRIAL ADVOCACY National Session (Boulder, Colorado) - July, 1999 UNIVERSITY OF HOUSTON LAW CENTER Juris Doctorate - December, 1994 Houston Journal oflnternational Law, Research Editor Phi Delta Phi Honors Fraternity UNIVERSITY OF TEXAS AT AUSTIN Bachelor of Arts, History - December, 1991 MEMBERSHIPS: Texas State Bar Utah State Bar California State Bar Oklahoma State Bar Nevada State Bar Pennsylvania State Bar Missouri State Bar Kansas State Bar Tennessee State Bar Florida State Bar Management Association (2001 - present) Healthcare Financial American College of Healthcare Executives (2010 — present) American Association 0f Healthcare Administrative Management (2018 — present) EXHIBIT B THE TUREK LAW FIRM PC TIMESHEET THE TUREK LAW FIRM pc Dale Hours UTBMS task code (ABA) Communicate (other outside cuunsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Phone call with Marcus Plan and prepare for L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Review communication from Plan and prepare for L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and (ABA! Communicate (other outside counsel) L110 Fact L110 Fact Review matter draft letter to TPL verification of check (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and phone call with o/c re: status of checking Tn with insurance company,- and Administration with via e-mail Communicate (other outside counse‘) L160 Settlement/Non-Einding L160 ADR E-mail to Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Review matter draft demand letter to Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Revise demand letter Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and enclosure for dema nd letter Communicate L110 Fact L110 Fact Draf‘t/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Review/analyze L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and :review check received; phone (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Follow with (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Review matter with (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Phone call with review Comerica website re: affidavit of Review communication Revise affidavit of Communicate L120 L120 Review affidavit tn client (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Follow with re: indemnification in affidavit of (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Review case for send ermail to counse‘ on matter Drafl/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Review matter draft contact letter Plan and for L210 L210 L210 Research C200 L210 L210 L210 L210 Review revise PO P Research L210 L210 Research L210 L210 Communicate L120 L120 Communicate L210 L210 Research L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and exas SOS website research Communicate (with client) L190 Other Case Assessment, L190 Other Case Assessment, Development and and Administration Communicate (with client) L190 Other Case Assessment, L190 Other Case Assessment, Development and and Administration L210 L210 Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and demand exhibits L210 L210 Review for SOL details L210 L210 TIMESHEET THE TUREK LAW FIRM pc Communicate L210 Communicate Erin L210 POP Exhibit A Erin Communicate Erin Communicate L210 Erin L210 L210 to court Patricia McCulloch L210 Review citation revise letter to court Erin L210 L210 RFD Patricia McCulloch L210 L210 notice of of address Patricia McCulloch L310 Written I310 Written Review matter and revise draft RFD Erin L310 Written L310 Written to Comerica RFDs Turek L310 Written L3 10 Written Revise RFD instructions for of docs Erin for L140 L140 all dates contained on order Patricia McCulloch Review correspondence from Camerica atty; Review file, emails, and RFPs, voicemail m any; email L320 Document Production L320 Document Production and send Rule 11 Erin Plan and for L320 Document Production L320 Document Production Review D Comerica RFP' search emails for Erin L210 L210 RFP Patricia McCulloch Revise RFP responses; review production documents far redaction and privilege application; add'l due diligence L320 Document Production I320 Document Production for documents Erin L320 Document Production L320 Document Production Erin L320 Document Production L320 Document Production Erin L310 Written L3 10 Written Tu rek L320 Document Production L320 Document Production Erin L320 Document Production L320 Document Production Patricia McCulloch L320 Document Production L320 Document Production Final review 0f documents for redaction materials Erin L210 L210 draft lst Amended Petition Erin Research C200 Law Law Erin L140 L140 . Patricia McCulloch Communicate L120 L120 Patricia McCulloch (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration to re mediator Erin Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Review from re mediator draft letter to court Erin Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Letter lo Court Re Mediator L310 Written L310 Written Draft RFP INT to Cherokee and Comerica L310 Written L310 Written L310 Written L310 Written m Comerica Research P270 Reviews P270 Reviews Communicate P300 P300 Research P270 Reviews P270 Reviews Communicate P300 F300 Research P270 Reviews P270 Reviews Communicate P300 P300 Research C200 Law L210 L210 L310 Written L3 10 Written Review (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration with Marcus continuance L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Draft Mtn for order L240 Motions L240 Motions Draft draft affidavits L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Motion for T Continence L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Mtn for Continuance finalized and sent to Communicate L160 ADR L160 ADR Communicate (other outside counse‘) L160 Settlement/Non—Binding L160 ADR to Cherokee Erin L140 L140 reviewed Patricia McCulloch L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions Draft order calculate dates Erin TIMESHEET THE TUREK LAW FIRM PC Draft/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Draf‘t/revise L190 Other Case Assessment, Development and L190 Other Case Assessment, Development and Revise Communicate L120 L120 Research P270 Reviews P270 Reviews Research P270 Reviews P270 Reviews (ABA! Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration on USO Erin L440 Other Trial and L440 Other Trial and Review and deadhnes on lit calendar Patricia McCulloch L440 Other Trial and L440 Other Trial and Reviewed local ru‘es for deadlines. Patricia McCulloch L210 L210 Erin Research L240 Motions L240 Motions Erin Communicate (other outside counse‘) L160 Settlemenl/Non-Binding L160 with Erin Communicate L160 ADR L160 with Erin L240 Motions L240 Mnflons review Erin L240 Motions L240 Motions Nunsuit for Comerica Communicate (other outside counse‘) L160 Settlement/Non-Binding L160 ADR Follow email to Erin (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration Follow to Comerica re MSJ Erin L210 L210 finalize lst Am Pet for Erin L160 ADR L160 ADR Draft Rule 11 dismissal Comerica Erin L160 ADR L160 ADR and send Rule 11 to Comerica Erin Communicate L160 ADR L160 ADR Erin (ABA) Communicate (other outside counsel) L190 Other Case L190 Other Case Assessment, Development and and Administration to Comerica re MSJ removal Erin L250 Other Written Motions and Submissions L250 Other Written Motions and Submissions revise exhibits Erin L140 L140 timesheet Patricia McCulloch Total Hours 6 EXHIBIT C THE TUREK LAW FIRM PC TUREK DEVORE, PC JESSICA D. GUOBAIMA‘: RUSS DEVOREak 25227 Grogans Mill Road, Suite 100A J_ ERIN LOWINSHE" Junm E MYERQW The Woodlands, Texas 77330 ASSOCIATES Telephone: (281) 296—6920 DOUGLAS D TURFK+' ’ Facsimile: (281) 296-0733 PATRICIA MCCULLOCH www.turekdevore.c0n1 LISA SCOGGINS LEGAL :KSSIsl'AN'rS May 29, 2014 Paul Leslie General Counsel Attention: Brenda Neel Hight Parkland Health & Hospital System 520] Harry Hines Boulevard Dallas, Texas 75235 Re: Retention Agreement between Parkland Health & Hospital System and Turek DeVore, PC Dear Ms. Hight: Pursuant t0 our recent conversations, Parkland Health 3c Hospital System (“Parkland”) has decided t0 continue t0 retain Turek DeVore, PC (“TDV”) to represent Parkland in a variety of matters, inciuding, but not limited to General Litigation and Account Collections. Parkland and TDV agree that this letter will serve a5 the agraement that controls TDV’s representation of Parkland. I. GENERAL LITIGATION Parkland has decided to retain Turek DeVore, PC (“TDV”) to pursue and de fend non- account legal claims, as the need arises (“Representation”). ' Licensed in Calilbrnla, Kansas. Missouri, Nm'ada, Oklahoma, Punm‘yh'ania. Tennuesste. Texas. and Utah "' Licensed in Cnlurudu, New Mexico. Oklahoma, and 'l‘exas 'Liitensed in Culif'urnia :Ind Texas “Licensed in Illinois 3nd Texas ~ Licensed in Texas B. Fees and Expenses 1. Contingency Fees and Expenses For matters in which Parkland is seeking a recovery from a third party, Parkland agrees that it pay TDV twenty-two and one-half percent (22.5%) ofall recovered funds prior t0 suit will being filed by any party and twenty—five percent (25%) of all recovered funds afier suit is filed by either Parkland 0r a Third-Party. In these matters,TDV will absorb the expenses 0f litigation, except in cases in which Turek notifies Parkland TDV reasonably believes expenses exceed a reasonable amount if that Parkland seeks to continue litigation. In such matters Parkiand will reimburse TDV expenses upon appropriate documentation. Additionally, in cases in which it becomes apparent that Parkland may be any alleged wrongdoing, TDV agrees to timely advise Parkland of liable for such potential exposure. Parkland remains responsible for any amounts adjudged against or otherwise agreed to be paid by Parkland. 2. Hourlv Fees and Expenses For referrals to TDV t0 defend Parkland or in which Parkland is not seeking affirmative monetary relief, Parkland agrees to pay TDV the following hourly rates: Hourly Rate Discounted Rate Douglas Turek $ 350.00fhour $ 250.00fh0ur Jessica Guobadia $ 250.00fhour $ 175.00fh0ur Erin Lowinske $ 150.00fhour $ 125.00fh0ur Legal Assistants $ 75.00fl10ur $ 50.00fh0ur Parkland will be responsible for any expenses incurred in which TDV is retained t0 defend Parkland 0n an hourly basis. TDV will review expenses with Parkland: including discovery expenses, prior to incurring such expenses. [n cases in which it becomes apparant that Parkland may be any alieged wrongdoing, Parkland remains responsible for any liable for amounts adjudged against or otherwise agreed t0 be paid by Parkland. Iv. WI: This letter and the Parkland Counsel Guidelines constitute the entire terms 0f the engagement 0f TDV in the Representation. These written terms of engagement are not subject to any oral agreements or understandings, and they can ha modified only by further mitten agreement signed both by Parkland and TDV. If this letter accurately reflects the agreement between Parkiand and TDV, please sign in the: space provided below and send the signed letter back to our office. By signing baiow, you acknowledga that you have thc authority to bind Parkland to this agreement. If you have any questions or revisions, please call me 0r Jessica Guobadia at (231) 296-6920. We look forward t_o working with Parkland 0n these matters. It is our hope that cantinuing this relationship results in future. success for Parkland. As always, thank yau for the opportunity. Do glas D. Turek dturek@turel