Preview
Electronically Filed
2/13/2024 8:24 AM
Hidalgo County District Clerks
Reviewed By: Dianira Leal
CAUSE NO. C-0474-21-D
Noel Arturo ZAMORA, Jr., §
Plaintiff, § 206th JUDICIAL DISTRICT COURT
§
v. §
§
Reynaldo SALINAS-REYNA, Individually, §
and REYNALDO R. SALINAS, § HIDALGO COUNTY, TEXAS
Defendants §
PLAINTIFF’S SECOND SUPPLEMENTAL NOTICE OF FILING
MEDICAL AND BILLING RECORDS
PLEASE TAKE NOTICE that the attached documents, being copies of medical and medical
billing records pertaining to Plaintiff Noel Arturo ZAMORA, Jr., accompanied and proven by
notarized affidavits were obtained from the following:
8. Affidavit Concerning Cost & Necessity of Services of Dimple Kaur (dated
1/12/24), Custodian of Records for Capital Brain & Spine;
9. Affidavit of Medical Records of Dimple Kaur (dated 1/12/24), Custodian of
Records for Capital Brain & Spine;
10. Updated Affidavit Concerning Cost & Necessity of Services of Viola Cantu
(dated 2/12/24), Custodian of Records for Rio Grande Valley Orthopedic
Center;
11. Affidavit of Updated Medical Records of Viola Cantu (dated 2/12/24),
Custodian of Records for Rio Grande Valley Orthopedic Center;
12. Updated Affidavit Concerning Cost & Necessity of Services of Marivel Torrez
(dated 2/12/24), Custodian of Records for Southern Texas MRI Center;
13. Affidavit of Updated Medical Records of Marivel Torrez (dated 2/12/24),
Custodian of Records for Southern Texas MRI Center;
14. Deposition on Written Questions by Maricela Salinas (dated 7/7/21), Custodian
of Medical Records for Family Medical & Specialty Clinic;
15. Deposition on Written Questions by Maricela Salinas (dated 7/7/21), Custodian
of Billing Records for Family Medical & Specialty Clinic;
16. Deposition on Written Questions by Maricela Salinas (dated 1/16/23),
Custodian of Billing Records for Family Medical & Specialty Clinic;
Page 1 of 4
Electronically Filed
2/13/2024 8:24 AM
Hidalgo County District Clerks
Reviewed By: Dianira Leal
17. Deposition on Written Questions by Maricela Salinas (dated 10/20/22),
Custodian of Medical Records for Family Medical & Specialty Clinic;
18. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of
Billing Records for Kay Medical Clinic;
19. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of
Medical & Radiology Records for Kay Medical Clinic;
20. Deposition on Written Questions by Luis I. Khit (dated 12/30/22), Custodian
of Billing Records for Kay Medical Clinic;
21. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of
Medical & Radiology Records for Khit Chiropractic & Wellness;
22. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of
Billing Records for Kay Medical Clinic;
23. Deposition on Written Questions by Luis I. Khit (dated 12/29/22), Custodian
of Billing Records for Kay Medical Clinic;
24. Deposition on Written Questions by John Goss (dated 9/16/21), Custodian of
Billing Records for McAllen Medical Center;
25. Deposition on Written Questions by John Goss (dated 1/5/22), Custodian of
Billing Records for McAllen Medical Center;
26. Deposition on Written Questions by Juan Carlos Aguirre (dated 9/13/21),
Custodian of Radiology Records for McAllen Medical Center;
27. Deposition on Written Questions by Marivel Perez (dated 8/9/21), Custodian
of Medical Records for McAllen Medical Center;
28. Deposition on Written Questions by Sandra SaBell (dated 7/8/21), Custodian
of Billing Records for MedCare EMS;
29. Deposition on Written Questions by Sandra SaBell (dated 7/8/21), Custodian
of Medical Records for MedCare EMS;
30. Deposition on Written Questions by Justine Schnepp (dated 1/16/23),
Custodian of Billing Records for MedCare EMS;
31. Deposition on Written Questions by Viola Cantu (dated 8/2/21), Custodian of
Billing Records for Rio Grande Valley Orthopedic Center;
32. Deposition on Written Questions by Viola Cantu (dated 8/2/21), Custodian of
Medical Records for Rio Grande Valley Orthopedic Center;
Page 2 of 4
Electronically Filed
2/13/2024 8:24 AM
Hidalgo County District Clerks
Reviewed By: Dianira Leal
33. Deposition on Written Questions by Marivel Torrez (dated 8/2/21), Custodian
of Billing Records for Southern Texas MRI Center;
34. Deposition on Written Questions by Marivel Torrez (dated 8/9/21), Custodian
of Medical Records for Southern Texas MRI Center;
35. Deposition on Written Questions by Laura Erica Mata (dated 7/28/21),
Custodian of Billing Records for UT Health RGV Multispecialty;
36. Deposition on Written Questions by Laura Erica Mata (dated 7/28/21),
Custodian of Medical Records for UT Health RGV Multispecialty;
37. Deposition on Written Questions by Laura Erica Mata (dated 1/16/23),
Custodian of Billing Records for UT Health RGV Multispecialty;
38. Deposition on Written Questions by Laura Erica Mata (dated 1/27/23),
Custodian of Medical Records for UT Health RGV Multispecialty;
39. Deposition on Written Questions by Annabel Andrade Mata (dated 7/8/21),
Custodian of Billing Records for Waltham Consultants, P.A.;
40. Deposition on Written Questions by Annabel Andrade Mata (dated 7/8/21),
Custodian of Medical Records for Waltham Consultants, P.A.; and
41. Deposition on Written Questions by Juan Lozoya (dated 1/9/23), Custodian of
Billing Records for Waltham Consultants, P.A.
Such documents are filed pursuant to Rule 902(4) and (10) of the Texas Rules of
Evidence and §18.001 of the Civil Practice and Remedies Code and may be offered into
evidence in this cause. True and correct copies of said medical and billing records have been
produced to opposing counsel either through discovery or through deposition on written
questions or are being produced concurrently with this filing.
Respectfully submitted,
GONZÁLEZ & ASSOCIATES LAW FIRM, LTD.
Summit Park North
817 E. Esperanza Ave.
McAllen, TX 78501
Tel. No. (956) 664-0100
Fax No. (956) 664-1529
______________________________
Page 3 of 4
Electronically Filed
2/13/2024 8:24 AM
Hidalgo County District Clerks
Reviewed By: Dianira Leal
Jaime A. González, Jr.
Jaime@jaglawfirm.com
State Bar No. 08127600
Catherine W. Smith
cat@jaglawfirm.com
State Bar No. 18547080
Attorneys for Plaintiff
Designated E-Service E-mail Address: The following
is the designation of electronic service e-mail address for
the above attorney(s) for all electronically served
documents and notices, filed and unfiled, pursuant to
Tex. R. Civ. P. 21(f)(2) and 21(a):
courtfiling@jaglawfirm.com. This is the ONLY
electronic service e-mail address for the above
attorney(s), and service through any other e-mail address
will be considered invalid.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been
forwarded to opposing counsel in accordance with T.R.C.P. 21a, on this the 13th day of
February, 2024.
Via e-service
Messrs. Larry J. Goldman, Julian Dominguez
GOLDMAN & PETERSON, PLLC
10100 Reunion Place, Suite 800
San Antonio, TX 78216
Attorneys for Defendants
__________________________________
Catherine W. Smith
Page 4 of 4
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.
Roxanna Crowe on behalf of Jaime A. Gonzalez, Jr.
Bar No. 08127600
roxanna@jaglawfirm.com
Envelope ID: 84433781
Filing Code Description: Notice
Filing Description: Plf's 2nd Supplemental Notice of Filing Medical &
Billing Records
Status as of 2/13/2024 8:32 AM CST
Associated Case Party: Reynaldo Salinas-Reyna
Name BarNumber Email TimestampSubmitted Status
LARRY JGOLDMAN LARRY@LJGLAW.COM 2/13/2024 8:24:30 AM SENT
JULIAN RDOMINGUEZ JULIAN@LJGLAW.COM 2/13/2024 8:24:30 AM SENT
Associated Case Party: Reynaldo R. Salinas
Name BarNumber Email TimestampSubmitted Status
Larry J.Goldman mail@LJGLaw.com 2/13/2024 8:24:30 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JAIME GONZALEZ JAIME@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT
CATHERINE SMITH CAT@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT
CS COURTFILING@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT
JAIME GONZALEZ roxanna@jaglawfirm.com 2/13/2024 8:24:30 AM SENT
Preview
Electronically Filed 2/13/2024 8:24 AM Hidalgo County District Clerks Reviewed By: Dianira Leal CAUSE NO. C-0474-21-D Noel Arturo ZAMORA, Jr., § Plaintiff, § 206th JUDICIAL DISTRICT COURT § v. § § Reynaldo SALINAS-REYNA, Individually, § and REYNALDO R. SALINAS, § HIDALGO COUNTY, TEXAS Defendants § PLAINTIFF’S SECOND SUPPLEMENTAL NOTICE OF FILING MEDICAL AND BILLING RECORDS PLEASE TAKE NOTICE that the attached documents, being copies of medical and medical billing records pertaining to Plaintiff Noel Arturo ZAMORA, Jr., accompanied and proven by notarized affidavits were obtained from the following: 8. Affidavit Concerning Cost & Necessity of Services of Dimple Kaur (dated 1/12/24), Custodian of Records for Capital Brain & Spine; 9. Affidavit of Medical Records of Dimple Kaur (dated 1/12/24), Custodian of Records for Capital Brain & Spine; 10. Updated Affidavit Concerning Cost & Necessity of Services of Viola Cantu (dated 2/12/24), Custodian of Records for Rio Grande Valley Orthopedic Center; 11. Affidavit of Updated Medical Records of Viola Cantu (dated 2/12/24), Custodian of Records for Rio Grande Valley Orthopedic Center; 12. Updated Affidavit Concerning Cost & Necessity of Services of Marivel Torrez (dated 2/12/24), Custodian of Records for Southern Texas MRI Center; 13. Affidavit of Updated Medical Records of Marivel Torrez (dated 2/12/24), Custodian of Records for Southern Texas MRI Center; 14. Deposition on Written Questions by Maricela Salinas (dated 7/7/21), Custodian of Medical Records for Family Medical & Specialty Clinic; 15. Deposition on Written Questions by Maricela Salinas (dated 7/7/21), Custodian of Billing Records for Family Medical & Specialty Clinic; 16. Deposition on Written Questions by Maricela Salinas (dated 1/16/23), Custodian of Billing Records for Family Medical & Specialty Clinic; Page 1 of 4 Electronically Filed 2/13/2024 8:24 AM Hidalgo County District Clerks Reviewed By: Dianira Leal 17. Deposition on Written Questions by Maricela Salinas (dated 10/20/22), Custodian of Medical Records for Family Medical & Specialty Clinic; 18. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of Billing Records for Kay Medical Clinic; 19. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of Medical & Radiology Records for Kay Medical Clinic; 20. Deposition on Written Questions by Luis I. Khit (dated 12/30/22), Custodian of Billing Records for Kay Medical Clinic; 21. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of Medical & Radiology Records for Khit Chiropractic & Wellness; 22. Deposition on Written Questions by Luis I. Khit (dated 7/16/21), Custodian of Billing Records for Kay Medical Clinic; 23. Deposition on Written Questions by Luis I. Khit (dated 12/29/22), Custodian of Billing Records for Kay Medical Clinic; 24. Deposition on Written Questions by John Goss (dated 9/16/21), Custodian of Billing Records for McAllen Medical Center; 25. Deposition on Written Questions by John Goss (dated 1/5/22), Custodian of Billing Records for McAllen Medical Center; 26. Deposition on Written Questions by Juan Carlos Aguirre (dated 9/13/21), Custodian of Radiology Records for McAllen Medical Center; 27. Deposition on Written Questions by Marivel Perez (dated 8/9/21), Custodian of Medical Records for McAllen Medical Center; 28. Deposition on Written Questions by Sandra SaBell (dated 7/8/21), Custodian of Billing Records for MedCare EMS; 29. Deposition on Written Questions by Sandra SaBell (dated 7/8/21), Custodian of Medical Records for MedCare EMS; 30. Deposition on Written Questions by Justine Schnepp (dated 1/16/23), Custodian of Billing Records for MedCare EMS; 31. Deposition on Written Questions by Viola Cantu (dated 8/2/21), Custodian of Billing Records for Rio Grande Valley Orthopedic Center; 32. Deposition on Written Questions by Viola Cantu (dated 8/2/21), Custodian of Medical Records for Rio Grande Valley Orthopedic Center; Page 2 of 4 Electronically Filed 2/13/2024 8:24 AM Hidalgo County District Clerks Reviewed By: Dianira Leal 33. Deposition on Written Questions by Marivel Torrez (dated 8/2/21), Custodian of Billing Records for Southern Texas MRI Center; 34. Deposition on Written Questions by Marivel Torrez (dated 8/9/21), Custodian of Medical Records for Southern Texas MRI Center; 35. Deposition on Written Questions by Laura Erica Mata (dated 7/28/21), Custodian of Billing Records for UT Health RGV Multispecialty; 36. Deposition on Written Questions by Laura Erica Mata (dated 7/28/21), Custodian of Medical Records for UT Health RGV Multispecialty; 37. Deposition on Written Questions by Laura Erica Mata (dated 1/16/23), Custodian of Billing Records for UT Health RGV Multispecialty; 38. Deposition on Written Questions by Laura Erica Mata (dated 1/27/23), Custodian of Medical Records for UT Health RGV Multispecialty; 39. Deposition on Written Questions by Annabel Andrade Mata (dated 7/8/21), Custodian of Billing Records for Waltham Consultants, P.A.; 40. Deposition on Written Questions by Annabel Andrade Mata (dated 7/8/21), Custodian of Medical Records for Waltham Consultants, P.A.; and 41. Deposition on Written Questions by Juan Lozoya (dated 1/9/23), Custodian of Billing Records for Waltham Consultants, P.A. Such documents are filed pursuant to Rule 902(4) and (10) of the Texas Rules of Evidence and §18.001 of the Civil Practice and Remedies Code and may be offered into evidence in this cause. True and correct copies of said medical and billing records have been produced to opposing counsel either through discovery or through deposition on written questions or are being produced concurrently with this filing. Respectfully submitted, GONZÁLEZ & ASSOCIATES LAW FIRM, LTD. Summit Park North 817 E. Esperanza Ave. McAllen, TX 78501 Tel. No. (956) 664-0100 Fax No. (956) 664-1529 ______________________________ Page 3 of 4 Electronically Filed 2/13/2024 8:24 AM Hidalgo County District Clerks Reviewed By: Dianira Leal Jaime A. González, Jr. Jaime@jaglawfirm.com State Bar No. 08127600 Catherine W. Smith cat@jaglawfirm.com State Bar No. 18547080 Attorneys for Plaintiff Designated E-Service E-mail Address: The following is the designation of electronic service e-mail address for the above attorney(s) for all electronically served documents and notices, filed and unfiled, pursuant to Tex. R. Civ. P. 21(f)(2) and 21(a): courtfiling@jaglawfirm.com. This is the ONLY electronic service e-mail address for the above attorney(s), and service through any other e-mail address will be considered invalid. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded to opposing counsel in accordance with T.R.C.P. 21a, on this the 13th day of February, 2024. Via e-service Messrs. Larry J. Goldman, Julian Dominguez GOLDMAN & PETERSON, PLLC 10100 Reunion Place, Suite 800 San Antonio, TX 78216 Attorneys for Defendants __________________________________ Catherine W. Smith Page 4 of 4 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. Roxanna Crowe on behalf of Jaime A. Gonzalez, Jr. Bar No. 08127600 roxanna@jaglawfirm.com Envelope ID: 84433781 Filing Code Description: Notice Filing Description: Plf's 2nd Supplemental Notice of Filing Medical & Billing Records Status as of 2/13/2024 8:32 AM CST Associated Case Party: Reynaldo Salinas-Reyna Name BarNumber Email TimestampSubmitted Status LARRY JGOLDMAN LARRY@LJGLAW.COM 2/13/2024 8:24:30 AM SENT JULIAN RDOMINGUEZ JULIAN@LJGLAW.COM 2/13/2024 8:24:30 AM SENT Associated Case Party: Reynaldo R. Salinas Name BarNumber Email TimestampSubmitted Status Larry J.Goldman mail@LJGLaw.com 2/13/2024 8:24:30 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status JAIME GONZALEZ JAIME@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT CATHERINE SMITH CAT@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT CS COURTFILING@JAGLAWFIRM.COM 2/13/2024 8:24:30 AM SENT JAIME GONZALEZ roxanna@jaglawfirm.com 2/13/2024 8:24:30 AM SENT