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CAUSE NO. 2020 79221
CHRISTOPHER PLEASANT IN THE DISTRICT COURT OF
VS. HARRIS COUNTY, TEXAS
TRANSOCEAN DRILLING (USA) INC.,
TRANSOCEAN OFFSHORE
DEEPWATER DRILLING, INC. AND
BEACON OFFSHORE ENERGY LLC 334TH JUDICIAL DISTRICT
PLAINTIFF’S NOTICE OF FILING BUSINESS RECORD AFFIDAVITS
Y ou are hereby notified that Plaintiff Christopher Pleasant has filed in the above
entitled and numbered cause the following business record affidavits:
Affidavit of Joy Ashford, the Custodian of Records for Neurosurgical Solutions of
Lafayette (RO0O R00009
Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness
R000063 R000097);
Affidavit of Kathy LaFleur, the Custodian of Records for Lafayette Surgical Specialty
Hospital R000 R000651
Affidavit of Kathy LaFleur, the Custodian of Records for Lafayette Surgical Specialty
Hospital R000661 RO00662
Affidavit of Gabrielle Cappel, the Custodian of Records for Medtek Specialties
R000663 R000670
Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness
R000681 R000694
Affidavit of Sillesia Mar, the Custodian of Records for Imperial Health Medical
R000698 R000760)
Affidavit of Brenna Peavy, the Custodian of Records for NeuroDiagnostic Monitoring
R000767 R000794
Affidavit of a William A. Brennan, the Custodian of Records for Neur urgical
Solutions of Lafayette LLC (R000795 R000944
Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN LA
R000948 R000965
Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN LA
R000966 R000967);
Affidavit of Stacie Miller, the Custodian of Records for Allied Health (R000982
RO01003);
Affidavit of Gabrielle Loftin, the Custodian of Records for Express Scripts Pharmacy
RO01004 R001011
14. Affidavit of Roxie Lapara, the Custodian of Records for Injury Meds Pharmacy
(R001012-R001020);
15. Affidavit of Jackie Reed, the Custodian of Records for Memorial Medical Group
(R001025-R001029);
16. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions
of Lafayette, LLC (R001040-R001055);
17. Affidavit of Jean Hawks, the Custodian of Records for Dr. Jean M. Hawks, PhD.
(R001060-R001070);
18. Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness
(R001075-R001078);
19. Affidavit of Roxie Lapara, the Custodian of Records for Injury Meds (R001079-
RO01100);
20. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions
of Lafayette, LLC (R001112-R001160);
21. Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN-LA
(R001164-R001171);
22. Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN-LA
(R001172-R001173);
23. Affidavit of Camryn Bell, the Custodian of Records for Orthopaedic Reconstructive
Subspecialists, LLC (R001177-R0012270);
24. Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness
(R001247-R001250);
25. Affidavit of Melanie Wikerson, the Custodian of Records for Allied Health (R001262-
RO01290);
26. Affidavit of Tim Myers, the Custodian of Records for Injury Meds (R001291-
RO01314);
27. Affidavit of Tim Myers, the Custodian of Records for Injury Meds (R001315-
RO01338);
28. Affidavit of Sheena Jack, the Custodian of Records for Allied Health (R001343-
RO01352);
29. Affidavit of Dr. M.K. Hamza Ph.D., the Custodian of Records for Neurobehavioral
Clinic (R001353-R001382);
30. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions
of Lafayette, LLC (R001395-R001444).
These records will be offered in evidence at the trial of the captioned cause.
Pursuant to Rule 902(10)(a) of the Texas Rules of Evidence, these records will be
made available by counsel for Plaintiff for inspection and copying at the expense of the
person desiring the copies. In addition, Pursuant to Rule 902(10)(a) of the Texas Rules of
Evidence these affidavits are being filed with the clerk of the court at least fourteen days
before the day on which evidence is to be presented at the trial of the captioned cause.
Respectfully Submitted,
ARNOLD & ITKIN LLP
/s/ Roland Christensen
—-- + ——-
Kurt Amold
SBN: 24036150
kamold@ amolditkin.com
Caj Boatright
SBN: 24036237
cboatright@ amolditkin.com
Roland Christensen
SBN: 24101222
rchristensen@ amolditkin.com
6009 Memorial Drive
Houston, Texas 77007
Tel: 713.222.3800
Fax: 713.222.3850
e-service@ amolditkin.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been forwarded to all
counsel of record on November 20, 2023.
/s/ Roland Christensen
Roland Christensen
SOUT RN TPA UME INT SOLU CIONS
LA124
Medical Records/BHESg Certification. Letter
Date 4] 2¢/Z Certified Pages lb (Number)
Dear: eX las (Requestor)
RE: Chu stopher Pleasant (Patient Name)
‘Livl 1943 (DOB)
NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southem
Medical Document Solutions, LLC, for the purpose of copying and releasing copies of
medical records that you have requested.
,
I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et
seq., as amended, I hereby certify that the attached are true and complete (to the best of
my knowledge) photocopies of the medical records and/or billing statements that were
received from NEUROSURGICAL SOLUTIONS OF LAFAYETTE * on the above
refer ed patient in order to produce requested copies of the contents.
LY Lh 4[z5] 2
oT ica Docume fotutohs LLC Date
As a representative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify
pursuant to La. R.S. 13:3714 et seq., as amended, that the enclosed medical records
and/or billing statements on the above referenced patient are a true and correct copy
originating from this facility and created during the nogmal course of business. This
medical record has been provided to Southern Medig ocument olutions, LLC, for
reproduction per your request.
Signature of Medical Records Librarian
|
Printed Name gf Medjcal Records Librarian. Wullliom A. Data vad)
Date 7g
Certified Copy of Medical Records and/or Billing Statement
*X-Ra MRI, CAT Scans and/or radiology film are not kept with this fa ite
ena as /3s
lo
28/91
wy
Low
BARBARA G. CEFALU
Notary Public
Notary ID #41285
East Baton Rouge Parish
State of Louisiana
Lifetime Commission
C. Pleasant
RO00005
No,
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
Type ofRecords: Any and all medical records, pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906,
including but not limited to: any and all emergency room records, history and physicals, admission and discharge
summaries, radiology reports, pathology reports, flow sheets, medication and/or prescription logs-including samples
log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs,
archived records, any and all documents which may be contained in patient file from other care providers, including
patient information sheet, handwritten notes, telephone messages, electronic media and any correspondence pertaining to
the patient,
Before me, the undersigned authority, personally appeared AlliVino Be rand .
who, being by me duly sworn, deposed as follows: (Custodian of Records)
wy names Fie Bey wow A I am over eighteen (18) years of age, of sound
mind, capable of making this affidavit, and personally acquainted with the facts herein stated:
Tam the Custodian of Records for:
Elite Medical Wellness
Attached hereto are 3 2 pages of records from this facility. The attached records are for the dates of service from
\ \ 170 to L BiU . These records are kept in the regular course of business, and it was the
regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion,
or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was
made at or near the time or reasonably soon thereafier, The records attached hereto are the original or exact duplicates of the
original.
Mine
bubay|
AFFIANT (Custodian of Records)
Sworn to and subscribed before me on the 222 day of an 2d /
Wes COLE. Keg
ee Es 2 Liga
Commi ion Expires:
Spot
As
DEAE
ive
Order No. 341328.004
C. Pleasant
ROO0064
LAFAYETTE SURGICAL
\ SPECIALTY HOSPITAL
s+ PROUDLY PHYSICIAN OWNED —~
Certification of Medical Records
|, Kathy LaFleur, RHIA, custodian of records at Lafayette Surgical Specialty
Hospital certify that the attached records are a true and exact copy of all the
original records in our custody for Christopher Pleasant,
These records were kept in the regular course of business,
22
oa Imation Manager
C. Pleasant
R000280
oh
Bn af facet at
LAFAYETTE SURGICAL
\ SPECIALTY HOSPITAL
— PROUDLY PHYSICIAN OWNED —
1101 Kaliste Saloom Rd Phone 337-769-4204 Fax 337-769-4199
an of Medical Records
|, Kathy LaFleur, RHIA, custodian of records at Lafayette Surgical Specialty
Hospital certify that’ the attached Radiology films are a true and exact copy of
all the original records in our custody for
Christopher Pleasant
These records were keptin the regular course of business.
4/1/2022
Health Info Manager Date
b
ke
mieten ta
C. Pleasant
ROOO662
CERTIFICATION FOR COPIES OF MEDICAL/BILLING RECORDS
MED TEK SPECIALTIES
P.O. Box 383
Lake Charles, LA 70602
ve. Wristopher Racal cae Dshin|a003
Z Pages: bo
I, GABRIELLE CAPPEL, do certify that the attached medical/billing records for the above
mentioned patient are the entire medical records we have in our possession for this patient, and these are
true copies of all medical records.
OR
I do certify that no medical records have ever been
maintained for the above mentioned patient.
Fetowlseep
C. Pleasant
ROOO664
No.
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
Type of Records: Any and all medical records, FROM 02/04/2021 TO THE PRESENT, pertaining to Christopher
Pleasant, DOB: 01/18/1973, SSN: xxx: 1906, including but not limited to: any and all emergency room records,history
and physicals, admission and discharge summaries, radiology reports, pathology reports, flow sheets, medication and/or
prescription logs-including samples log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy
records, correspondence, photographs, archived records, any and all documents which may be contained in patient file
from other care providers, including patient information shcet, handwritten notes, telephone messages, electronic media
and any correspondence pertaining to the patient.
Before me, the undersigned authority, personally appeared Allison Bevtrand
who, being by me duly sworn, deposed as follows: (Custodian of Records)
viynmes ANison Bevtvand Tam over eighteen (18) ycars of age, of sound
mind, capable of making this affidavit, and personally acquainted with the facts herein stated:
Tam the Custodian of Records for
Elite Medical Wellness
Attached her 0 are pagep of ords from this facility, The attached records are for the dates of service from
to ZZICOTZ. these records are kept in the regular course of business, and it was the
regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion.
or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was
made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
original
Ale: Belecal
AFFIANT (Custodian of Records)
Sworn to and subscribed before me on the 2% fey0 of Lb! Ped
Dalidlbe Metz.
PO Liars Lebefrnre
We ee
hy Commission Expires:
Order No. 341328.025
C. Pleasant
ROO0682
a
SOUTHERN MEDICAL DOCUMENT SOLUTIONS
LA107
\Medical RecordyBilling Certification
ON, yaw
Date S/ne/2032 Certified Pages GB\ (Number)
TO: Lex ras (Requestor)
RE: Cyc \Srapine £ Precasan (Patient Name)
\ } \]AANS (DOB)
IMPERIAL HEALTH is contracted with Southern Medical Document Solutions, LLC,
for the purpose of copying and releasing copies of medical records that you have
requested.
I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et
seq., as amended, I hereby certify that the attached are true and complete (to the best of
my knowledge) photocopies of the medical records and/or billing statements that were
received from IMPERIAL HEALTH * on the above referenced patient in order to
produce requested copies of the contents.
Riverton Mod ab’/aNd2
Southern Medical Document Solutions, LLC Date
As a representative of IMPERIAL HEALTH, I certify pursuant to La. R.S. 13:3714 et
seq., as amended, that the enclosed medical records and/or billing statements on the
above referenced patient are a true and correct copy originating from this facility and
created during the normal course of business. This medical record has been provided to
Southern Medical Document Solutions, LLC, forreproduction per your request.
/
Signature of Medical Records Librarian A for Whataic A A Bene
A
a
Printed Name of Medical Records Librarian ya WA fae
Date: S/Q6/2022
Certified Copy of Medical Records and/or Billing Statement
*X-Ra MRI,C. Scans and/or radiolo: film are not kept with this*rad)
medical records. MEMES
a BoD.
Notary Public
Notary ID #41285
East Baton Rouge Parish
State of Louisiana
| ifetima Cammieeina
C. Pleasant
ROO0699
3lue (6/7) 03/22/2022 02:24:18 PM -O500
No
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
Type of Records: Any and all medical records, pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906
including but not limited to: any and all emergency room records, history and physicals, admission and discharge
summaries, radiology reports, pathology reports, flow sheets, medication and/or prescription logs-including samples
log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs,
archived records, any and all documents which may be contained in patient file from other care providers, including
patient information sheet, handwritten notes, telephone messages, electronic media and any correspondence pertaining to
the patient.
Before me, the undersigned authority, personally appeared Brenna Peavy
who, being by me duly sworn, deposed as follows (Custodian of Records)
My name is Brenna Peavy » lam over eighteen (18) years of age, of sound
mind, capable of making this affidavit, and personally’ acquainted with the facts herein stated:
Iam the Custodian of Records for:
NeuroDiagnostic Monitoring
Attached hereto are 2 \0_ pages of records from this facility. The attached records are for the dates of service from
10/2% {2020 to presen . These records are kept in the regular course of business, and it was the
regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion,
or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was
made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
original.
Sworn to and subscribed before me on the qr day of york 20 9-)-
\
ea
NOTARY BUBLIC i
My Commission Expires: (@ ade
Order No. 341328.021
C. Pleasant
ROO00768
ANAC
SOUTHERN MEDICAL
laa
DOCUMENT
Jer
Medical Records/Billing Certification Letter
SOLUTION
LA124
Datela
a| Moa Certified Pages \+ f (Number)
Dear: Cages (Requestor)
ne, Chiuatyphr. Plpocan € (Patient Name)
\ 1S (DOB)
NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southern
Medical Document Solutions, LLC, for the purpose of copying and releasing copies of
medical records that you have requested.
I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et
seq., as amended, I hereby certify that the attached are true and complete (to the best of
my knowledge) photose of the medical records and/or billing statements that were
received from ‘UROSURG OGUTIONS OF LAFAYETTE * on the above
referenced ygtient in order to p; ested copies of the contents.
Sla¢ [oa
Southern Medical Docuntent Solutions, LLC Date
As a representative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify
pursuant to La. R.S. 13:3714 et seq., as amended, that the enclosed medical records
and/or billing statements on the above referenced patient are a true and correct copy
originating from this facility and created during the noi al course of business. This
medical record has been provided to Southern Medic; locument, lutions, LLC, for
reproduction per your request.
Signature of Medical Records Librarian.
Printed Nj iene Records Librarian__taslblLiom A- Bntw vat)
Date: ala
Certified Copy of Medical Records and/or Billing Statement
*X-Ra MRI, CAT Scans
meliadranrisy shand/or >_radiolo; cn film_are
Leva not Lat
kept with
A this fecility
ens tots
ov tad, Yr tho
a]am\y032 BARBARA G. CEFALU
Aoarlinc Gu
Public
Notary ID # 41285
East Baton Rouge Pasish
State of Louisiana
Lifetime Commission
C. Pleasant
RO000796
ALLE
Diagnostic Imaging Services
L Tammy Coco medical record custodian do
hereby certify that the attached is a true and correct copy of the
medical record and images for Christopher Pleasant
This 25" day of April, 2022.
\
2. (a
Medical Record Custodian
Tammy Coco
04/25/2022
Date
Open Air MRI of Cen-La
5413 Jackson St. Ext., Suite A ~ Alexandria, LA 71303-2322
318-445-OPEN ~ 318-445-8009 ~ 318-445-8845 (fax) ~ www.openairmri.com
C. Pleasant
R000949
sounommasti
— i AY Ted |
“Diagnostic Imaging Services
L Tammy Coco medical record custodian do
hereby certify that the attached is a true and correct copy of the
medical record and images for Christopher Pleasant
This 25" day of April, 2022.
=
Zz
)
Vv
q ~
(M24)
Medical Record Custodian
Tammy Coco
04/25/2022
Date
Open Air MRI of Cen-La
5413 Jackson St, Ext., Suite A ~ Alexandria, LA 71303-2322
318-445-OPEN ~ 318-445-8009 ~ 318-445-8845 (fax) ~ www.openairmri.com
C. Pleasant
R000967
No,
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
‘Type of Records: Any and all medical records FR OM
12/16/2021 TO THE PRESENT, + Pertaining to Christopher Pleasant,
DOB: 01/18/1973, SSN: xxx-xx-1906, including but not limited
to: any and all emergency room records, history and
Physicals, admission and discharge summaries, radiolo
gy repo} rts, » pathology reports, flow sheets, medication and/or
Prescription logs-including samples log(s), nurses notes,
consulta tions, tests, test results, diagnoses, prognoses, therapy
records, correspondence, photographs, archived records, any
ai nd all documents which may be contained in patient file
from other care providers, including patient information
sheet, handwritten notes, telephone messages, electronic media
Caentl
and any correspondence pertaining to the patient.
Before me, the undersigned authority, personally appeared
who, being by me duly sworn, deposed as follows: —
(Custodian of Records)
My name is TAA AAW » Lam over eighteen (18) years of age, of sound
mind, capable of making this affidavit, and personally acquainted with
the facts herein stated:
Tam the Custodian of Records for:
Allied Health
“ti war
T pare rds from this facility. The attached records are for the dates of service
9 + These records are kept in the regular course of business, and it was
regular course of f business for an employeelor represent tative of this facility, with
from
the
knowledge of the act, event, condition, opinion,
or diagnosis, recorded to make the record or to transmit information thereof
to be included in such record; and the record was
made at or near the time or reasonably soon thereafter. The records attached
hereto are the original or exact duplicates of the
original.
pT
ef b REEVES AFFIANT (Custodian of Records)
MA
ss ne %
OTA)" %
Sy}
before me on the 2 day of = no
rm Y
St .
———______
a, Sey jetenne®
panies
Sr
p NOTARY PUBLIC
Rr
My Commiston pes lepn kagy” igi -
Order No. 341328.033
C. Pleasant
R000983
BUS ESS RECORDS AFFIDAVIT
STATE OF MISSOURI
) SS
COUNTY OF ST. LOUIS )
Before me, the undersigned authority, personally appeared GABRIELLE LOFTIN who, being by me duly
sworn, deposed as follows
My name is GABRIELLE LOFTIN. | am over the age 18, capable of making this affidavit, and
personally acquainted with the facts herein stated
As of April 2012, Express Scripts Holding Company became the parent company of Express Scripts, Inc.
Medco Health Solutions, Inc., and all of their respective subsidiaries (collectively referred to as “Express Scripts”).
I hereby certify that the search of pharmacy benefit manager prescription claims records from our database
revealed that the named patient, CHRISTOPHER B PLEASANT, has the attached records available. This does
not mean that other records do not exist under another spelling, another name, or another classification, but based
upon the information furnished to our office, and to the best of our knowledge, the records provided to you are
accurate,
These records are kept by Express Scripts, Inc. in the regular course of business, and it was the regular
course of business of Express Scripts, Inc. for an employee or representative of Express Scripts, Inc. with
knowledge of the act, event, condition, or opinion recorded to make the record or to transmit information thereofto
be included in such record: and the record was made at or near the time of the act, event, condition, or opinion. The
records attached hereto are electronically stored and are produced in Express Scripts, Inc.’s standard usable format
Dated this _6™ day of OCTOBER 2022
EXPRESS SCRIPTS, INC
ay Wjtness whereof, I have hereunto subscribed my name and affixed my official seal this ON day of
Oote r _, 2022.
Bete LOZ eee Ta
Poet TY
PUDIC oe
My Commission Expires Ne Seal
of
Hi
33: 740
10141 1v1 19-2024
thse 165383.1
C. Pleasant
R001005
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
Type of Records: ANY AND ALL PHARMACY RECORDS, FROM 12/2/2021 TO THE PRESENT, INCLUDING NDC
CODES, all prescriptions records, medical equipment leased and/or purchased, billing records and/or statements, and
any other tangible documents pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906.
Before me, the undersigned authority, personally appeared
who, being by me duly swom, deposed as follows: (Custodian of Records)
My name is I am over eighteen (18) years of age, of sound
mind, capable of making this affidavit, and personally acquainted with the facts herein stated:
1 am the Custodian of Records for: InjuryMeds
Attached to this affidavit are records that provide an itemized statement of the services and the charges for the services
that this facility provided to the above-named person from [PEQEMPEr
2O2\ to TT 2022 The attached
records are a part of this affidavit.
The attached records are kept by this facility in the regular course of business, and it was the regular course of business
of this facility for an employee or representative of this facility, with knowledge of the service provided, to make the record or to
transmit information to be included in the record. The records were made in the regular course of business at or near the time or
reasonably soon after the time the service was provided. The records are the original or a duplicate of the original.
The services provided were necessary and the amount charged for the services were reasonable at the time and place that
the services were provided.
The total amount paid for the services was $_\~1,441Le AN. The amount currently unpaid which the facility has
arightto be paid after any adjustments or credits is $
AFFIANT (Custodian of Records)
‘Sworn to and subscribed before me on the \\W4> day of Pruaust 20 22
NOTARY PUBLIC
My Commission Expires: Li we
Order No. 341328.035
BRADY MOUTON
Notary Public
State of Louisiana
Lafayette Parish
Notary
ID #057185
My Commission is for Life
C. Pleasant
R001013
CIO <
MEDICAL / BILLS / RADIOLOGY RECORDS CERTIFICATION
I Jackie Reed, a medical record reproduction representative employed by Ciox Health, the HIM
service used by Memorial Medical Group certify that the enclosed copy of medical records for
Christopher Pleasant compared with the original records and is an accurate duplicate of such records.
A The attached records are made at or near the time of the occurrence of the matters set forth in
the documents;
B. The attached records were made by a person with knowledge of those matters, or from
information transmitted by a person with knowledge of those matters:
The attached records were made and kept in the course of regularly conducted business
activity; and
The attached records were made and kept by the business as a regular practice.
Packie Reed
Ciox Representative
08/05/2022
Date
X___ Complete Chart Complete Bills Complete Radiology
Films
Incomplete Chart Incomplete Bills Radiology Films Mailed
C. Pleasant
R001026
(OA08 SOUTHERN MEDICAL DOCUMENT
Medical Reena
SOLUTIONS
Certification-Letter
LA124
3.95. FF - PRESENT
pan Yue cntoorrae Hf one
Dear: DY TAS (Requestor)
ne: (HesTerHer tLeasdait (Patient Name)
div 493 (DOB)
NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southern
Medical Document Solutions, LLC, for the purpose of copying and releasing copies of
medical records that you have requested.
I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et
seq., as amended, I hereby certify that the attached are true and complete (to the best of
my knowledge) photocopies of the medical records and/or billing statements that were
received from NEUROSURGICAL SOLUTIONS OF LAFAYETTE * on the above
referenced patient in order to produce requested copies of the contents.
J
A
Southern Medical Document Solutions, LLC Di ate
Wi
As-a tepresentative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify
pursuant to La,.R.S, 13:3714 et seq, as amended, that the enclosed medical records
and/or billing statements on the above referenced patient are a true and correct copy
originating from this facility and created during the no ‘al course of business. This
medical record has been provided to Southern Medic; ocument lutions, LLC, for
reproduction per your request.
Signature of Medical Records Librarian.
Date: it
Printed Name of Medical oe Lollliom A+ Batwa)
Certified ach Medical Records and/or Billing Statement
*X-Ray, MRI, CAT, Scans and/or _radiolo: film _are not kept ’s
medical records.
~ aft) psy,
AI G. CEFALUL
Pox
a
Notary Public
ota ry ID #44285
jotai
East Baton Rouge Parish
State of Louisiana
Lifetime Commission
C. Pleasant
R001041
No.
AFFIDAVIT
Records Pertaining To: Christopher Pleasant
Type of Records: ANY AND ALL MEDICAL AND/OR COUNSELING RECORDS, FROM 01/26/2022 TO THE
PRESENT, including but not limited to any type of doctor's or counselor's notes; any patient information sheets; any
patient evaluation forms; any type of insurance records; any type of report and/or office notes; printouts of any type of
medical data stored on any computer hard-drive(s), diskette(s), tape(s), and/or CD-ROMS; any type of correspondence
pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906
Before me, the undersigned authority, personally appeared equ bn Ws
who, being by me duly sworn, deposed as follows: (Custodian of Records)
My name is Jedh Hawks Tam over eighteen (18) years of age, of sound
mind, capable of making this affidavit, and personally acquainted with the facts herein stated:
Tam the Custodian of Records for:
Dr. Jean M. Hawks, PhD
gG
Attached hereto are pages of records from this facility. The attached records are for the dates of service from
£ 2Y {22 to 1fi2 [2X . These records are kept in the regular course of business, and it was the
regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion,
>
or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was
made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the
original.
AFEJAN 'T (Custodian of1
de aah
Sworn to and subscribed before me on the /Q th day ot toler 4a 74 2043.
(a
Adeborn 0. SySdeee
Notary Public State of Florida Mak PUBLIC
Barbara Ann MacNeill
3 oy Conmattic
Preview
CAUSE NO. 2020 79221 CHRISTOPHER PLEASANT IN THE DISTRICT COURT OF VS. HARRIS COUNTY, TEXAS TRANSOCEAN DRILLING (USA) INC., TRANSOCEAN OFFSHORE DEEPWATER DRILLING, INC. AND BEACON OFFSHORE ENERGY LLC 334TH JUDICIAL DISTRICT PLAINTIFF’S NOTICE OF FILING BUSINESS RECORD AFFIDAVITS Y ou are hereby notified that Plaintiff Christopher Pleasant has filed in the above entitled and numbered cause the following business record affidavits: Affidavit of Joy Ashford, the Custodian of Records for Neurosurgical Solutions of Lafayette (RO0O R00009 Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness R000063 R000097); Affidavit of Kathy LaFleur, the Custodian of Records for Lafayette Surgical Specialty Hospital R000 R000651 Affidavit of Kathy LaFleur, the Custodian of Records for Lafayette Surgical Specialty Hospital R000661 RO00662 Affidavit of Gabrielle Cappel, the Custodian of Records for Medtek Specialties R000663 R000670 Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness R000681 R000694 Affidavit of Sillesia Mar, the Custodian of Records for Imperial Health Medical R000698 R000760) Affidavit of Brenna Peavy, the Custodian of Records for NeuroDiagnostic Monitoring R000767 R000794 Affidavit of a William A. Brennan, the Custodian of Records for Neur urgical Solutions of Lafayette LLC (R000795 R000944 Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN LA R000948 R000965 Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN LA R000966 R000967); Affidavit of Stacie Miller, the Custodian of Records for Allied Health (R000982 RO01003); Affidavit of Gabrielle Loftin, the Custodian of Records for Express Scripts Pharmacy RO01004 R001011 14. Affidavit of Roxie Lapara, the Custodian of Records for Injury Meds Pharmacy (R001012-R001020); 15. Affidavit of Jackie Reed, the Custodian of Records for Memorial Medical Group (R001025-R001029); 16. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions of Lafayette, LLC (R001040-R001055); 17. Affidavit of Jean Hawks, the Custodian of Records for Dr. Jean M. Hawks, PhD. (R001060-R001070); 18. Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness (R001075-R001078); 19. Affidavit of Roxie Lapara, the Custodian of Records for Injury Meds (R001079- RO01100); 20. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions of Lafayette, LLC (R001112-R001160); 21. Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN-LA (R001164-R001171); 22. Affidavit of Tammy Coco, the Custodian of Records for Open Air MRI of CEN-LA (R001172-R001173); 23. Affidavit of Camryn Bell, the Custodian of Records for Orthopaedic Reconstructive Subspecialists, LLC (R001177-R0012270); 24. Affidavit of Allison Bertrand, the Custodian of Records for Elite Medical Wellness (R001247-R001250); 25. Affidavit of Melanie Wikerson, the Custodian of Records for Allied Health (R001262- RO01290); 26. Affidavit of Tim Myers, the Custodian of Records for Injury Meds (R001291- RO01314); 27. Affidavit of Tim Myers, the Custodian of Records for Injury Meds (R001315- RO01338); 28. Affidavit of Sheena Jack, the Custodian of Records for Allied Health (R001343- RO01352); 29. Affidavit of Dr. M.K. Hamza Ph.D., the Custodian of Records for Neurobehavioral Clinic (R001353-R001382); 30. Affidavit of William A. Brennan, the Custodian of Records for Neurosurgical Solutions of Lafayette, LLC (R001395-R001444). These records will be offered in evidence at the trial of the captioned cause. Pursuant to Rule 902(10)(a) of the Texas Rules of Evidence, these records will be made available by counsel for Plaintiff for inspection and copying at the expense of the person desiring the copies. In addition, Pursuant to Rule 902(10)(a) of the Texas Rules of Evidence these affidavits are being filed with the clerk of the court at least fourteen days before the day on which evidence is to be presented at the trial of the captioned cause. Respectfully Submitted, ARNOLD & ITKIN LLP /s/ Roland Christensen —-- + ——- Kurt Amold SBN: 24036150 kamold@ amolditkin.com Caj Boatright SBN: 24036237 cboatright@ amolditkin.com Roland Christensen SBN: 24101222 rchristensen@ amolditkin.com 6009 Memorial Drive Houston, Texas 77007 Tel: 713.222.3800 Fax: 713.222.3850 e-service@ amolditkin.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been forwarded to all counsel of record on November 20, 2023. /s/ Roland Christensen Roland Christensen SOUT RN TPA UME INT SOLU CIONS LA124 Medical Records/BHESg Certification. Letter Date 4] 2¢/Z Certified Pages lb (Number) Dear: eX las (Requestor) RE: Chu stopher Pleasant (Patient Name) ‘Livl 1943 (DOB) NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southem Medical Document Solutions, LLC, for the purpose of copying and releasing copies of medical records that you have requested. , I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et seq., as amended, I hereby certify that the attached are true and complete (to the best of my knowledge) photocopies of the medical records and/or billing statements that were received from NEUROSURGICAL SOLUTIONS OF LAFAYETTE * on the above refer ed patient in order to produce requested copies of the contents. LY Lh 4[z5] 2 oT ica Docume fotutohs LLC Date As a representative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify pursuant to La. R.S. 13:3714 et seq., as amended, that the enclosed medical records and/or billing statements on the above referenced patient are a true and correct copy originating from this facility and created during the nogmal course of business. This medical record has been provided to Southern Medig ocument olutions, LLC, for reproduction per your request. Signature of Medical Records Librarian | Printed Name gf Medjcal Records Librarian. Wullliom A. Data vad) Date 7g Certified Copy of Medical Records and/or Billing Statement *X-Ra MRI, CAT Scans and/or radiology film are not kept with this fa ite ena as /3s lo 28/91 wy Low BARBARA G. CEFALU Notary Public Notary ID #41285 East Baton Rouge Parish State of Louisiana Lifetime Commission C. Pleasant RO00005 No, AFFIDAVIT Records Pertaining To: Christopher Pleasant Type ofRecords: Any and all medical records, pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906, including but not limited to: any and all emergency room records, history and physicals, admission and discharge summaries, radiology reports, pathology reports, flow sheets, medication and/or prescription logs-including samples log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs, archived records, any and all documents which may be contained in patient file from other care providers, including patient information sheet, handwritten notes, telephone messages, electronic media and any correspondence pertaining to the patient, Before me, the undersigned authority, personally appeared AlliVino Be rand . who, being by me duly sworn, deposed as follows: (Custodian of Records) wy names Fie Bey wow A I am over eighteen (18) years of age, of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: Tam the Custodian of Records for: Elite Medical Wellness Attached hereto are 3 2 pages of records from this facility. The attached records are for the dates of service from \ \ 170 to L BiU . These records are kept in the regular course of business, and it was the regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time or reasonably soon thereafier, The records attached hereto are the original or exact duplicates of the original. Mine bubay| AFFIANT (Custodian of Records) Sworn to and subscribed before me on the 222 day of an 2d / Wes COLE. Keg ee Es 2 Liga Commi ion Expires: Spot As DEAE ive Order No. 341328.004 C. Pleasant ROO0064 LAFAYETTE SURGICAL \ SPECIALTY HOSPITAL s+ PROUDLY PHYSICIAN OWNED —~ Certification of Medical Records |, Kathy LaFleur, RHIA, custodian of records at Lafayette Surgical Specialty Hospital certify that the attached records are a true and exact copy of all the original records in our custody for Christopher Pleasant, These records were kept in the regular course of business, 22 oa Imation Manager C. Pleasant R000280 oh Bn af facet at LAFAYETTE SURGICAL \ SPECIALTY HOSPITAL — PROUDLY PHYSICIAN OWNED — 1101 Kaliste Saloom Rd Phone 337-769-4204 Fax 337-769-4199 an of Medical Records |, Kathy LaFleur, RHIA, custodian of records at Lafayette Surgical Specialty Hospital certify that’ the attached Radiology films are a true and exact copy of all the original records in our custody for Christopher Pleasant These records were keptin the regular course of business. 4/1/2022 Health Info Manager Date b ke mieten ta C. Pleasant ROOO662 CERTIFICATION FOR COPIES OF MEDICAL/BILLING RECORDS MED TEK SPECIALTIES P.O. Box 383 Lake Charles, LA 70602 ve. Wristopher Racal cae Dshin|a003 Z Pages: bo I, GABRIELLE CAPPEL, do certify that the attached medical/billing records for the above mentioned patient are the entire medical records we have in our possession for this patient, and these are true copies of all medical records. OR I do certify that no medical records have ever been maintained for the above mentioned patient. Fetowlseep C. Pleasant ROOO664 No. AFFIDAVIT Records Pertaining To: Christopher Pleasant Type of Records: Any and all medical records, FROM 02/04/2021 TO THE PRESENT, pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx: 1906, including but not limited to: any and all emergency room records,history and physicals, admission and discharge summaries, radiology reports, pathology reports, flow sheets, medication and/or prescription logs-including samples log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs, archived records, any and all documents which may be contained in patient file from other care providers, including patient information shcet, handwritten notes, telephone messages, electronic media and any correspondence pertaining to the patient. Before me, the undersigned authority, personally appeared Allison Bevtrand who, being by me duly sworn, deposed as follows: (Custodian of Records) viynmes ANison Bevtvand Tam over eighteen (18) ycars of age, of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: Tam the Custodian of Records for Elite Medical Wellness Attached her 0 are pagep of ords from this facility, The attached records are for the dates of service from to ZZICOTZ. these records are kept in the regular course of business, and it was the regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion. or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original Ale: Belecal AFFIANT (Custodian of Records) Sworn to and subscribed before me on the 2% fey0 of Lb! Ped Dalidlbe Metz. PO Liars Lebefrnre We ee hy Commission Expires: Order No. 341328.025 C. Pleasant ROO0682 a SOUTHERN MEDICAL DOCUMENT SOLUTIONS LA107 \Medical RecordyBilling Certification ON, yaw Date S/ne/2032 Certified Pages GB\ (Number) TO: Lex ras (Requestor) RE: Cyc \Srapine £ Precasan (Patient Name) \ } \]AANS (DOB) IMPERIAL HEALTH is contracted with Southern Medical Document Solutions, LLC, for the purpose of copying and releasing copies of medical records that you have requested. I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et seq., as amended, I hereby certify that the attached are true and complete (to the best of my knowledge) photocopies of the medical records and/or billing statements that were received from IMPERIAL HEALTH * on the above referenced patient in order to produce requested copies of the contents. Riverton Mod ab’/aNd2 Southern Medical Document Solutions, LLC Date As a representative of IMPERIAL HEALTH, I certify pursuant to La. R.S. 13:3714 et seq., as amended, that the enclosed medical records and/or billing statements on the above referenced patient are a true and correct copy originating from this facility and created during the normal course of business. This medical record has been provided to Southern Medical Document Solutions, LLC, forreproduction per your request. / Signature of Medical Records Librarian A for Whataic A A Bene A a Printed Name of Medical Records Librarian ya WA fae Date: S/Q6/2022 Certified Copy of Medical Records and/or Billing Statement *X-Ra MRI,C. Scans and/or radiolo: film are not kept with this*rad) medical records. MEMES a BoD. Notary Public Notary ID #41285 East Baton Rouge Parish State of Louisiana | ifetima Cammieeina C. Pleasant ROO0699 3lue (6/7) 03/22/2022 02:24:18 PM -O500 No AFFIDAVIT Records Pertaining To: Christopher Pleasant Type of Records: Any and all medical records, pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906 including but not limited to: any and all emergency room records, history and physicals, admission and discharge summaries, radiology reports, pathology reports, flow sheets, medication and/or prescription logs-including samples log(s), nurses notes, consultations, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs, archived records, any and all documents which may be contained in patient file from other care providers, including patient information sheet, handwritten notes, telephone messages, electronic media and any correspondence pertaining to the patient. Before me, the undersigned authority, personally appeared Brenna Peavy who, being by me duly sworn, deposed as follows (Custodian of Records) My name is Brenna Peavy » lam over eighteen (18) years of age, of sound mind, capable of making this affidavit, and personally’ acquainted with the facts herein stated: Iam the Custodian of Records for: NeuroDiagnostic Monitoring Attached hereto are 2 \0_ pages of records from this facility. The attached records are for the dates of service from 10/2% {2020 to presen . These records are kept in the regular course of business, and it was the regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. Sworn to and subscribed before me on the qr day of york 20 9-)- \ ea NOTARY BUBLIC i My Commission Expires: (@ ade Order No. 341328.021 C. Pleasant ROO00768 ANAC SOUTHERN MEDICAL laa DOCUMENT Jer Medical Records/Billing Certification Letter SOLUTION LA124 Datela a| Moa Certified Pages \+ f (Number) Dear: Cages (Requestor) ne, Chiuatyphr. Plpocan € (Patient Name) \ 1S (DOB) NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southern Medical Document Solutions, LLC, for the purpose of copying and releasing copies of medical records that you have requested. I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et seq., as amended, I hereby certify that the attached are true and complete (to the best of my knowledge) photose of the medical records and/or billing statements that were received from ‘UROSURG OGUTIONS OF LAFAYETTE * on the above referenced ygtient in order to p; ested copies of the contents. Sla¢ [oa Southern Medical Docuntent Solutions, LLC Date As a representative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify pursuant to La. R.S. 13:3714 et seq., as amended, that the enclosed medical records and/or billing statements on the above referenced patient are a true and correct copy originating from this facility and created during the noi al course of business. This medical record has been provided to Southern Medic; locument, lutions, LLC, for reproduction per your request. Signature of Medical Records Librarian. Printed Nj iene Records Librarian__taslblLiom A- Bntw vat) Date: ala Certified Copy of Medical Records and/or Billing Statement *X-Ra MRI, CAT Scans meliadranrisy shand/or >_radiolo; cn film_are Leva not Lat kept with A this fecility ens tots ov tad, Yr tho a]am\y032 BARBARA G. CEFALU Aoarlinc Gu Public Notary ID # 41285 East Baton Rouge Pasish State of Louisiana Lifetime Commission C. Pleasant RO000796 ALLE Diagnostic Imaging Services L Tammy Coco medical record custodian do hereby certify that the attached is a true and correct copy of the medical record and images for Christopher Pleasant This 25" day of April, 2022. \ 2. (a Medical Record Custodian Tammy Coco 04/25/2022 Date Open Air MRI of Cen-La 5413 Jackson St. Ext., Suite A ~ Alexandria, LA 71303-2322 318-445-OPEN ~ 318-445-8009 ~ 318-445-8845 (fax) ~ www.openairmri.com C. Pleasant R000949 sounommasti — i AY Ted | “Diagnostic Imaging Services L Tammy Coco medical record custodian do hereby certify that the attached is a true and correct copy of the medical record and images for Christopher Pleasant This 25" day of April, 2022. = Zz ) Vv q ~ (M24) Medical Record Custodian Tammy Coco 04/25/2022 Date Open Air MRI of Cen-La 5413 Jackson St, Ext., Suite A ~ Alexandria, LA 71303-2322 318-445-OPEN ~ 318-445-8009 ~ 318-445-8845 (fax) ~ www.openairmri.com C. Pleasant R000967 No, AFFIDAVIT Records Pertaining To: Christopher Pleasant ‘Type of Records: Any and all medical records FR OM 12/16/2021 TO THE PRESENT, + Pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906, including but not limited to: any and all emergency room records, history and Physicals, admission and discharge summaries, radiolo gy repo} rts, » pathology reports, flow sheets, medication and/or Prescription logs-including samples log(s), nurses notes, consulta tions, tests, test results, diagnoses, prognoses, therapy records, correspondence, photographs, archived records, any ai nd all documents which may be contained in patient file from other care providers, including patient information sheet, handwritten notes, telephone messages, electronic media Caentl and any correspondence pertaining to the patient. Before me, the undersigned authority, personally appeared who, being by me duly sworn, deposed as follows: — (Custodian of Records) My name is TAA AAW » Lam over eighteen (18) years of age, of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: Tam the Custodian of Records for: Allied Health “ti war T pare rds from this facility. The attached records are for the dates of service 9 + These records are kept in the regular course of business, and it was regular course of f business for an employeelor represent tative of this facility, with from the knowledge of the act, event, condition, opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. pT ef b REEVES AFFIANT (Custodian of Records) MA ss ne % OTA)" % Sy} before me on the 2 day of = no rm Y St . ———______ a, Sey jetenne® panies Sr p NOTARY PUBLIC Rr My Commiston pes lepn kagy” igi - Order No. 341328.033 C. Pleasant R000983 BUS ESS RECORDS AFFIDAVIT STATE OF MISSOURI ) SS COUNTY OF ST. LOUIS ) Before me, the undersigned authority, personally appeared GABRIELLE LOFTIN who, being by me duly sworn, deposed as follows My name is GABRIELLE LOFTIN. | am over the age 18, capable of making this affidavit, and personally acquainted with the facts herein stated As of April 2012, Express Scripts Holding Company became the parent company of Express Scripts, Inc. Medco Health Solutions, Inc., and all of their respective subsidiaries (collectively referred to as “Express Scripts”). I hereby certify that the search of pharmacy benefit manager prescription claims records from our database revealed that the named patient, CHRISTOPHER B PLEASANT, has the attached records available. This does not mean that other records do not exist under another spelling, another name, or another classification, but based upon the information furnished to our office, and to the best of our knowledge, the records provided to you are accurate, These records are kept by Express Scripts, Inc. in the regular course of business, and it was the regular course of business of Express Scripts, Inc. for an employee or representative of Express Scripts, Inc. with knowledge of the act, event, condition, or opinion recorded to make the record or to transmit information thereofto be included in such record: and the record was made at or near the time of the act, event, condition, or opinion. The records attached hereto are electronically stored and are produced in Express Scripts, Inc.’s standard usable format Dated this _6™ day of OCTOBER 2022 EXPRESS SCRIPTS, INC ay Wjtness whereof, I have hereunto subscribed my name and affixed my official seal this ON day of Oote r _, 2022. Bete LOZ eee Ta Poet TY PUDIC oe My Commission Expires Ne Seal of Hi 33: 740 10141 1v1 19-2024 thse 165383.1 C. Pleasant R001005 AFFIDAVIT Records Pertaining To: Christopher Pleasant Type of Records: ANY AND ALL PHARMACY RECORDS, FROM 12/2/2021 TO THE PRESENT, INCLUDING NDC CODES, all prescriptions records, medical equipment leased and/or purchased, billing records and/or statements, and any other tangible documents pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906. Before me, the undersigned authority, personally appeared who, being by me duly swom, deposed as follows: (Custodian of Records) My name is I am over eighteen (18) years of age, of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: 1 am the Custodian of Records for: InjuryMeds Attached to this affidavit are records that provide an itemized statement of the services and the charges for the services that this facility provided to the above-named person from [PEQEMPEr 2O2\ to TT 2022 The attached records are a part of this affidavit. The attached records are kept by this facility in the regular course of business, and it was the regular course of business of this facility for an employee or representative of this facility, with knowledge of the service provided, to make the record or to transmit information to be included in the record. The records were made in the regular course of business at or near the time or reasonably soon after the time the service was provided. The records are the original or a duplicate of the original. The services provided were necessary and the amount charged for the services were reasonable at the time and place that the services were provided. The total amount paid for the services was $_\~1,441Le AN. The amount currently unpaid which the facility has arightto be paid after any adjustments or credits is $ AFFIANT (Custodian of Records) ‘Sworn to and subscribed before me on the \\W4> day of Pruaust 20 22 NOTARY PUBLIC My Commission Expires: Li we Order No. 341328.035 BRADY MOUTON Notary Public State of Louisiana Lafayette Parish Notary ID #057185 My Commission is for Life C. Pleasant R001013 CIO < MEDICAL / BILLS / RADIOLOGY RECORDS CERTIFICATION I Jackie Reed, a medical record reproduction representative employed by Ciox Health, the HIM service used by Memorial Medical Group certify that the enclosed copy of medical records for Christopher Pleasant compared with the original records and is an accurate duplicate of such records. A The attached records are made at or near the time of the occurrence of the matters set forth in the documents; B. The attached records were made by a person with knowledge of those matters, or from information transmitted by a person with knowledge of those matters: The attached records were made and kept in the course of regularly conducted business activity; and The attached records were made and kept by the business as a regular practice. Packie Reed Ciox Representative 08/05/2022 Date X___ Complete Chart Complete Bills Complete Radiology Films Incomplete Chart Incomplete Bills Radiology Films Mailed C. Pleasant R001026 (OA08 SOUTHERN MEDICAL DOCUMENT Medical Reena SOLUTIONS Certification-Letter LA124 3.95. FF - PRESENT pan Yue cntoorrae Hf one Dear: DY TAS (Requestor) ne: (HesTerHer tLeasdait (Patient Name) div 493 (DOB) NEUROSURGICAL SOLUTIONS OF LAFAYETTE is contracted with Southern Medical Document Solutions, LLC, for the purpose of copying and releasing copies of medical records that you have requested. I represent Southern Medical Document Solutions, LLC. Pursuant to La. R.S. 13:3714, et seq., as amended, I hereby certify that the attached are true and complete (to the best of my knowledge) photocopies of the medical records and/or billing statements that were received from NEUROSURGICAL SOLUTIONS OF LAFAYETTE * on the above referenced patient in order to produce requested copies of the contents. J A Southern Medical Document Solutions, LLC Di ate Wi As-a tepresentative of NEUROSURGICAL SOLUTIONS OF LAFAYETTE, I certify pursuant to La,.R.S, 13:3714 et seq, as amended, that the enclosed medical records and/or billing statements on the above referenced patient are a true and correct copy originating from this facility and created during the no ‘al course of business. This medical record has been provided to Southern Medic; ocument lutions, LLC, for reproduction per your request. Signature of Medical Records Librarian. Date: it Printed Name of Medical oe Lollliom A+ Batwa) Certified ach Medical Records and/or Billing Statement *X-Ray, MRI, CAT, Scans and/or _radiolo: film _are not kept ’s medical records. ~ aft) psy, AI G. CEFALUL Pox a Notary Public ota ry ID #44285 jotai East Baton Rouge Parish State of Louisiana Lifetime Commission C. Pleasant R001041 No. AFFIDAVIT Records Pertaining To: Christopher Pleasant Type of Records: ANY AND ALL MEDICAL AND/OR COUNSELING RECORDS, FROM 01/26/2022 TO THE PRESENT, including but not limited to any type of doctor's or counselor's notes; any patient information sheets; any patient evaluation forms; any type of insurance records; any type of report and/or office notes; printouts of any type of medical data stored on any computer hard-drive(s), diskette(s), tape(s), and/or CD-ROMS; any type of correspondence pertaining to Christopher Pleasant, DOB: 01/18/1973, SSN: xxx-xx-1906 Before me, the undersigned authority, personally appeared equ bn Ws who, being by me duly sworn, deposed as follows: (Custodian of Records) My name is Jedh Hawks Tam over eighteen (18) years of age, of sound mind, capable of making this affidavit, and personally acquainted with the facts herein stated: Tam the Custodian of Records for: Dr. Jean M. Hawks, PhD gG Attached hereto are pages of records from this facility. The attached records are for the dates of service from £ 2Y {22 to 1fi2 [2X . These records are kept in the regular course of business, and it was the regular course of business for an employee or representative of this facility, with knowledge of the act, event, condition, opinion, > or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. AFEJAN 'T (Custodian of1 de aah Sworn to and subscribed before me on the /Q th day ot toler 4a 74 2043. (a Adeborn 0. SySdeee Notary Public State of Florida Mak PUBLIC Barbara Ann MacNeill 3 oy Conmattic