On May 26, 2021 a
Party Statement
was filed
involving a dispute between
Alexander, Kevin,
and
Davis, Kenneth,
Keystone Automotive Industries, Inc.,
Lkq Corporation,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
5/26/2022 9:51 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rosa Delacerda DEPUTY
CAUSE NO. DC-21-06679
KEVIN ALEXANDER, IN THE DISTRICT COURT
Plaintiff,
v. 14TH JUDICIAL DISTRICT
KENNETH DAVIS AND LKQ
CORPORATION, DALLAS COUNTY, TEXAS
Defendants.
PLAINTIFF KEVIN RAY ALEXANDER'S NOTICE 0F FILING AFFIDAVITS
CONCERNING AUTHENTICITY OF MEDICAL EXPENSES PURSUANT TO
TEX.CIV.PRAC. & REM. CODES SECTION 18.001
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff Kevin Ray Alexander files this notice of service of the following
affidavits concerning authenticity of medical records and costs and necessity of
services in accordance with 902(10) of the Texas Rules of Evidence. The actual
affidavits produced by each custodian of records, along with the medical and billing
records to which they pertain, are not being filed with the Court. A copy of each
affidavit and the corresponding billing and medical records are being provided to
counsel as follows:
1. Affidavit(s) Concerning Costs and Necessity of Service for Prime Imaging
Partners - including billing records and medical records for Kevin Ray Alexander -
served via E-mail on May 26, 2022.
2. Affidavit(s) Concerning Costs and Necessity of Service for Radiology
Associates of North Texas - including billing records for Kevin Ray Alexander —
served via E-mail on May 26, 2022.
3. Affidavit(s) Concerning Costs and Necessity of Service for Texas Health
Presbyterian Hospital Dallas - including billing records and medical records for
Kevin Ray Alexander - served via E-mail on May 26, 2022.
EXPENSES PURSUANT TO TEX.CIV.PRAC. & REM. CODES SECTION 18.001 Page 1
4. Affidavit(s) Concerning Costs and Necessity of Service for Texas Medicine
Resources including billing records for Kevin Ray Alexander - served via
—
E—mail
on May 26, 2022.
Respectfully submitted,
/s/ James Bauguss lll
James Bauguss lll
State Bar No. 24045463
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(817) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document was
served on all counsel of record and/or pro se parties in accordance with Rules 21 and
21 a of the Texas Rules of Civil Procedure on this 26*“ day of May, 2022.
/s/ James Bauguss |||
James Bauguss lll
EXPENSES PURSUANT TO TEX.CIV.PRAC. & REM. CODES SECTION 18.001 Page 2
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Antonia Cavett on behalf of James Bauguss
Bar No. 24045463
antonia.cavett@benabbott.com
Envelope ID: 64875845
Status as of 5/26/2022 11:17 AM CST
Associated Case Party: KEYSTONE AUTOMOTIVE INDUSTRIES, INC.
Name BarNumber Email TimestampSubmitted Status
Eddy De Los Santos edelossantos@munsch.com 5/26/2022 9:51 :33 AM SENT
Cynthia Lujano clujano@munsch.com 5/26/2022 9:51:33 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Doreen Lungren doreen.lungren@benabbott.com 5/26/2022 9:51:33 AM SENT
Document Filed Date
May 26, 2022
Case Filing Date
May 26, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 5/26/2022 9:51 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rosa Delacerda DEPUTY CAUSE NO. DC-21-06679 KEVIN ALEXANDER, IN THE DISTRICT COURT Plaintiff, v. 14TH JUDICIAL DISTRICT KENNETH DAVIS AND LKQ CORPORATION, DALLAS COUNTY, TEXAS Defendants. PLAINTIFF KEVIN RAY ALEXANDER'S NOTICE 0F FILING AFFIDAVITS CONCERNING AUTHENTICITY OF MEDICAL EXPENSES PURSUANT TO TEX.CIV.PRAC. & REM. CODES SECTION 18.001 TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff Kevin Ray Alexander files this notice of service of the following affidavits concerning authenticity of medical records and costs and necessity of services in accordance with 902(10) of the Texas Rules of Evidence. The actual affidavits produced by each custodian of records, along with the medical and billing records to which they pertain, are not being filed with the Court. A copy of each affidavit and the corresponding billing and medical records are being provided to counsel as follows: 1. Affidavit(s) Concerning Costs and Necessity of Service for Prime Imaging Partners - including billing records and medical records for Kevin Ray Alexander - served via E-mail on May 26, 2022. 2. Affidavit(s) Concerning Costs and Necessity of Service for Radiology Associates of North Texas - including billing records for Kevin Ray Alexander — served via E-mail on May 26, 2022. 3. Affidavit(s) Concerning Costs and Necessity of Service for Texas Health Presbyterian Hospital Dallas - including billing records and medical records for Kevin Ray Alexander - served via E-mail on May 26, 2022. EXPENSES PURSUANT TO TEX.CIV.PRAC. & REM. CODES SECTION 18.001 Page 1 4. Affidavit(s) Concerning Costs and Necessity of Service for Texas Medicine Resources including billing records for Kevin Ray Alexander - served via — E—mail on May 26, 2022. Respectfully submitted, /s/ James Bauguss lll James Bauguss lll State Bar No. 24045463 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (817) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document was served on all counsel of record and/or pro se parties in accordance with Rules 21 and 21 a of the Texas Rules of Civil Procedure on this 26*“ day of May, 2022. /s/ James Bauguss ||| James Bauguss lll EXPENSES PURSUANT TO TEX.CIV.PRAC. & REM. CODES SECTION 18.001 Page 2 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Antonia Cavett on behalf of James Bauguss Bar No. 24045463 antonia.cavett@benabbott.com Envelope ID: 64875845 Status as of 5/26/2022 11:17 AM CST Associated Case Party: KEYSTONE AUTOMOTIVE INDUSTRIES, INC. Name BarNumber Email TimestampSubmitted Status Eddy De Los Santos edelossantos@munsch.com 5/26/2022 9:51 :33 AM SENT Cynthia Lujano clujano@munsch.com 5/26/2022 9:51:33 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Doreen Lungren doreen.lungren@benabbott.com 5/26/2022 9:51:33 AM SENT