Preview
FILED
3/12/2024 3:44 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC-23-03551
KASSANDRA WHITE AND IN THE DISTRICT COURT OF
BARBARA AGBANYIM
Plaintiff(s),
DALLAS COUNTY, TEXAS
PRACTICAL CARGO
SOLUTIONS, et al 134TH JUDICIAL DISTRICT
Defendant(s).
DEFENDANTS’ NOTICE OF SUBPOENA TO NON-PARTY
BAYLOR SCOTT & WHITE
TO Baylor Scott & White, by and through its registered agent, Corporation Service Company
d/b/a CSC-Lawyers Incorporating Service Company, 211 E. 7" Street, Suite 620, Austin,
Texas 78701.
TO Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246.
TO Plaintiff, Kassandra White, by and through their attorney of record, Brennan Clay,
Witherite Law Group, 10440 N. Central Expy, Suite 400, Dallas, TX 75231.
PLEASE TAKE NOTICE that, under Texas Rules of Civil Procedure 205 and 176.6(c),
Defendants Practical Cargo Solutions and Gary Dale Sr. intends to subpoena from Baylor Scott &
White the documents described in the attached Subpoena. The documents shall be produced for
inspection and copying on or before the expiration of twenty (20) days after the date of service at
10:00 a.m., at Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246, or at such earlier time
as may be ordered by this Court.
Page 1 of 7
Respectfully submitted,
{sf Sarah Dika
SARAH DIKA
State Bar No. 24131845
arah@fuentesfirm.com
The Fuentes Firm, P.C.
701 Commerce St, 5th Floor
Dallas, TX 75202
Telephone: (281) 378-7640
ATTORNEY FOR DEFENDANTS
PRACTICAL CARGO SOLUTIONS AND
GARY DALE SR.
CERTIFICATE OF SERVICE
Pursuant to the Texas Rules of Civil Procedure, a true and correct copy of the foregoing
has been served upon all counsel of record on February 6, 2024.
sf. Sarah Dika
SARAH DIKA
Page 2 of 7
CAUSE NO. DC-23-03551
KASSANDRA WHITE AND IN THE DISTRICT COURT OF
BARBARA AGBANYIM
Plaintiff(s),
DALLAS COUNTY, TEXAS
PRACTICAL CARGO
SOLUTIONS, et al 134TH JUDICIAL DISTRICT
Defendant(s).
SUBPOENA TO NON-PARTY BAYLOR SCOTT & WHITE
THE STATE OF TEXAS §
§
SUBPOENA §
WITNESS: BAYLOR SCOTT & WHITE
YOU ARE HEREBY COMMANDED TO PRODUCE ANY AND ALL DOCUMENTS AND
TANGIBLE ITEMS DESCRIBED ON EXHIBIT “A” ATTACHED HERETO.
TO PRODUCE AND PERMIT DATE: 20-days after service
INSPECTION AND COPYING OF TIME: 10:00 AM
DESIGNATED DOCUMENTS OR PLACE: Baylor Scott & White
TANGIBLE THINGS IN THE 3500 Gaston Ave
POSSESSION, CUSTODY, OR Dallas, TX 75246
CONTROL:
This subpoena was issued at the request of Defendants Practical Cargo Solutions and Gary Dale
Sr., whose attorney of record is:
Sarah Dika
State Bar No. 24131845
The Fuentes Firm, P.C.
5507 Louetta Road, Suite A
Spring, Texas 77379
Telephone: (281) 378-7640
CONTEMPT: FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO
OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE
DEEMED A CONTEMPT OF THE COURT FROM WHICH THE
SUBPOENA ISSUED OR A DISTRICT COURT IN THE COUNTY IN
WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED
BY FINE OR CONFINEMENT OR BOTH. Tex. R. Civ. P. 176.8(a).
Page 3 of 7
Issued on February 6, 2024.
{SL Sarah Dika
SARAH DIKA
State Bar No. 24131845
arah@fuentesfirm.com
The Fuentes Firm, P.C.
701 Commerce St, Sth Floor
Dallas, TX 75202
Telephone: (281) 378-7640
ATTORNEY FOR DEFENDANTS
PRACTICAL CARGO SOLUTIONS AND
GARY DALE SR.
Page 4 of 7
EXHIBIT A
The subpoenaed documents described below are related to the following described patient:
Patient Name: Kassandra White
Date of Birth: 7/23/1973
Address: 9620 Windridge Way, Dallas, TX 7521
Social Security No: XXX-XX-6977
All Medical records, Billing records, and Accounting records reflecting treatment, charges
billed, amounts paid, and adjustments, reductions or write-offs applied for medical services
provided to Kassandra White by Baylor Scott & White from 12/16/2011 to the present.
All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x-
ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes
any and all MRI films on CD and/or USB); all radiology reports, including but not limited to x-
ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related documents.
All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services
provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present,
including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed
care agreements, and chargemaster rates applicable to parties paying in cash.
All documents reflecting any insurance information provided by or on behalf of Kassandra
White to Baylor Scott & White in connection with medical services provided to Kassandra
White from 12/16/2021 to the present, including but limited to copies of any insurance cards
obtained, intake or admission forms providing any insurance information that would be
available to cover said medical services, and any correspondence from any insurer or employer
of Kassandra White identifying, denying or accepting coverage for said medical expenses.
All contracts and agreements between Baylor Scott & White and any of the following, or any
of their affiliates or agents, relating to or containing any contractual rates applicable to the
medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to
the present, including but not limited to any rate agreements, rate sheets, managed care
agreements, and chargemaster rates specific to each of the following:
Blue Cross Blue Shield,
United Healthcare,
Aetna,
Cigna,
Humana, and
any other insuring provider.
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Kassandra White the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
Page 5 of 7
whether any bills or charges for medical services provided to Kassandra White were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Kassandra White or their attorney relating to charges and
bills for medical services provided to Kassandra White from 12/16/2021 to the present,
including but not limited to any letters of protection, notices of responsible third party, letters
of guarantee, any correspondence relating to insurance, and any correspondence requesting that
charges be or not be submitted to an insurance provider.
All documents related to or concerning any claims submitted to any private insurer for charges
and bills for medical services provided to Kassandra White from 12/16/2021 to the present,
including but not limited to any claim forms, substantiating documents, acceptances or denials
from any private insurer, and any correspondence to any private insurer regarding a claim for
payment for said medical services.
All contracts and agreements between Baylor Scott & White any third-party financing, medical
factoring, or medical funding company relating to the sale or assignment of any medical claim
submitted or medical bill created, for the medical treatment provided Kassandra White from
12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual or
business relationship between Baylor Scott & White any third-party financing, medical
factoring, or medical funding company relating to any diagnosis or treatment given in
connection to Kassandra White from 12/16/2021 to the present.
10 All documents reflecting any payments made to or received from any third-party financing,
medical factoring, or medical funding company relating to the medical treatment provided to
Kassandra White from 12/16/2021 to the present.
11 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical diagnoses or treatment provided to Kassandra White from
12/16/2021 to the present.
12 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any contracts or agreements made in connection with the medical treatment
provided to Kassandra White from 12/16/2021 to the present.
13 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical claim submitted or medical bill created in connection with the
medical treatment provided to Kassandra White from 12/16/2021 to the present.
14 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
Page 6 of 7
company relating to any medical claim submitted or medical bill created in connection with the
medical treatment provided to Kassandra White from 12/16/2021 to the present.
15 All communications between Kassandra White and Baylor Scott & White including but not
limited to any correspondence, emails, text messages, telephone messages, visual voicemail or
internal notifications of pending voice messages, phone logs of calls or records of conversations,
and doctors or nurses’ notes and referrals.
16 All intake documents, history forms, patient questionnaires, intake forms, financial disclosures,
office records, inpatient and/or outpatient records relating to Kassandra White.
17 All documents related to how Kassandra White was referred to Baylor Scott & White,
including any referral emails or web forms.
18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments
potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome
of this litigation.
19 The complete contents of Baylor Scott & White’s Electronic Health Records (EHR) or
Electronic Medical Records (EMR), or any other such software relating to Kassandra White,
including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages,
Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab,
Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit
Log Reports, and Billable Submissions.
20 All marketing materials distributed to any member of Kassandra White’s present or past legal
team within the last three years.
21 All internal emails, chat room logs, text messages or other communications in any way related
to Kassandra White, their lawsuit, or their bills.
22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including
but not limited to Brennan Clay at Witherite Law Group.
Page 7 of 7
CAUSE NO. DC-23-03551
KASSANDRA WHITE AND IN THE DISTRICT COURT OF
BARBARA AGBANYIM
Plaintiff(s),
DALLAS COUNTY, TEXAS
PRACTICAL CARGO
SOLUTIONS, et al 134TH JUDICIAL DISTRICT
Defendant(s).
SUBPOENA TO NON-PARTY BAYLOR SCOTT & WHITE
THE STATE OF TEXAS §
§
SUBPOENA §
WITNESS: BAYLOR SCOTT & WHITE
YOU ARE HEREBY COMMANDED TO PRODUCE ANY AND ALL DOCUMENTS AND
TANGIBLE ITEMS DESCRIBED ON EXHIBIT “A” ATTACHED HERETO.
TO PRODUCE AND PERMIT DATE: 20-days after service
INSPECTION AND COPYING OF TIME: 10:00 AM
DESIGNATED DOCUMENTS OR PLACE: Baylor Scott & White
TANGIBLE THINGS IN THE 3500 Gaston Ave
POSSESSION, CUSTODY, OR Dallas, TX 75246
CONTROL:
This subpoena was issued at the request of Defendants Practical Cargo Solutions and Gary Dale Sr.,
whose attorney of record is:
Sarah Dika
State Bar No. 24131845
The Fuentes Firm, P.C.
5507 Louetta Road, Suite A
Spring, Texas 77379
Telephone: (281) 378-7640
CONTEMPT: FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO
OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE
DEEMED A CONTEMPT OF THE COURT FROM WHICH THE
SUBPOENA ISSUED OR A DISTRICT COURT IN THE COUNTY IN
WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY
FINE OR CONFINEMENT OR BOTH. Tex. R. Civ. P. 176.8(a).
Page | of 6
Issued on February 6, 2024.
{SL Sarah Dika
SARAH DIKA
State Bar No. 24131845
arah@fuentesfirm.com
The Fuentes Firm, P.C.
701 Commerce St, Sth Floor
Dallas, TX 75202
Telephone: (281) 378-7640
ATTORNEY FOR DEFENDANTS
PRACTICAL CARGO SOLUTIONS AND
GARY DALE SR.
Page 2 of 6
EXHIBIT A
The subpoenaed documents described below are related to the following described patient:
Patient Name: Kassandra White
Date of Birth: 7/23/1973
Address: 9620 Windridge Way, Dallas, TX 7521
Social Security No: XXX-XX-6977
All Medical records, Billing records, and Accounting records reflecting treatment, charges billed,
amounts paid, and adjustments, reductions or write-offs applied for medical services provided to
Kassandra White by Baylor Scott & White from 12/16/2011 to the present.
All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x-
ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes
any and all MRI films on CD and/or USB); all radiology reports, including but not limited to x-
ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related documents.
All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services
provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present,
including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed
care agreements, and chargemaster rates applicable to parties paying in cash.
All documents reflecting any insurance information provided by or on behalf of Kassandra White
to Baylor Scott & White in connection with medical services provided to Kassandra White from
12/16/2021 to the present, including but limited to copies of any insurance cards obtained, intake
or admission forms providing any insurance information that would be available to cover said
medical services, and any correspondence from any insurer or employer of Kassandra White
identifying, denying or accepting coverage for said medical expenses.
All contracts and agreements between Baylor Scott & White and any of the following, or any
of their affiliates or agents, relating to or containing any contractual rates applicable to the
medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the
present, including but not limited to any rate agreements, rate sheets, managed care agreements,
and chargemaster rates specific to each of the following:
Blue Cross Blue Shield,
United Healthcare,
Aetna,
Cigna,
Humana, and
any other insuring provider.
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Kassandra White the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
Page 3 of 6
whether any bills or charges for medical services provided to Kassandra White were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Kassandra White or their attorney relating to charges and
bills for medical services provided to Kassandra White from 12/16/2021 to the present, including
but not limited to any letters of protection, notices of responsible third party, letters of guarantee,
any correspondence relating to insurance, and any correspondence requesting that charges be or
not be submitted to an insurance provider.
All documents related to or concerning any claims submitted to any private insurer for charges
and bills for medical services provided to Kassandra White from 12/16/2021 to the present,
including but not limited to any claim forms, substantiating documents, acceptances or denials
from any private insurer, and any correspondence to any private insurer regarding a claim for
payment for said medical services.
All contracts and agreements between Baylor Scott & White any third-party financing, medical
factoring, or medical funding company relating to the sale or assignment of any medical claim
submitted or medical bill created, for the medical treatment provided Kassandra White from
12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual or
business relationship between Baylor Scott & White any third-party financing, medical
factoring, or medical funding company relating to any diagnosis or treatment given in connection
to Kassandra White from 12/16/2021 to the present.
10 All documents reflecting any payments made to or received from any third-party financing,
medical factoring, or medical funding company relating to the medical treatment provided to
Kassandra White from 12/16/2021 to the present.
11 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical diagnoses or treatment provided to Kassandra White from
12/16/2021 to the present.
12 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any contracts or agreements made in connection with the medical treatment
provided to Kassandra White from 12/16/2021 to the present.
13 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical claim submitted or medical bill created in connection with the
medical treatment provided to Kassandra White from 12/16/2021 to the present.
14 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
Page 4 of 6
company relating to any medical claim submitted or medical bill created in connection with the
medical treatment provided to Kassandra White from 12/16/2021 to the present.
15 All communications between Kassandra White and Baylor Scott & White including but not
limited to any correspondence, emails, text messages, telephone messages, visual voicemail or
internal notifications of pending voice messages, phone logs of calls or records of conversations,
and doctors or nurses’ notes and referrals.
16 All intake documents, history forms, patient questionnaires, intake forms, financial disclosures,
office records, inpatient and/or outpatient records relating to Kassandra White.
17 All documents related to how Kassandra White was referred to Baylor Scott & White, including
any referral emails or web forms.
18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments
potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome
of this litigation.
19 The complete contents of Baylor Scott & White’s electronic Health Records (EHR) or
Electronic Medical Records (EMR), or any other such software relating to Kassandra White,
including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages,
Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab,
Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit
Log Reports, and Billable Submissions.
20 All marketing materials distributed to any member of Kassandra White’s present or past legal
team within the last three years.
21 All internal emails, chat room logs, text messages or other communications in any way related
to Kassandra White, their lawsuit, or their bills.
22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including but
not limited to Brennan Clay at Witherite Law Group.
Page 5 of 6
PROOF OF SERVICE
Via Personal Service:
Baylor Scott & White
by and through its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating
Service Company
211 E. 7th Street, Suite 620
Austin, Texas 78701
Page 6 of 6
CAUSE NO. DC-23-03551
KASSANDRA WHITE AND IN THE DISTRICT COURT OF
BARBARA AGBANYIM
Plaintiff(s),
DALLAS COUNTY, TEXAS
PRACTICAL CARGO
SOLUTIONS, ET AL 134TH JUDICIAL DISTRICT
Defendant(s).
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
TO Baylor Scott & White, by and through its registered agent, Corporation Service Company
d/b/a CSC-Lawyers Incorporating Service Company, 211 E. 7" Street, Suite 620, Austin,
Texas 78701.
TO Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246.
TO Plaintiff, Kassandra White, by and through their attorney of record, Brennan Clay,
Witherite Law Group, 10440 N. Central Expy, Suite 400, Dallas, TX 75231.
TAKE NOTICE THAT twenty days after service of a copy hereof with attached questions, a
deposition by written questions will be taken of Baylor Scott & White, on the matters described
below in the DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS which are
attached hereto. This examination is requested at the address listed below:
BAYLOR SCOTT & WHITE
3500 GASTON AVE
DALLAS, TX 75246
Pursuant to Texas Rules of Civil Procedure 176.6(b), the named organization must designate one
or more officers, directors, or managing agents, or designate other persons to testify on its behalf;
and it may set out the matters on which each person designated will testify. The persons designated
must testify about information known or reasonably available to the organization.
This deposition with attached questions may be used as evidence upon the trial of the above-styled
and numbered cause pending in the above-named court. Notice is further given that request is
hereby made as authorized under Texas Rules of Civil Procedure 176 and 200 to the officer taking
this deposition to issue a subpoena and cause it to be served on the witness to bring and produce
for inspection and photocopying a true and correct copy of records described in the attached
Written Questions and to turn all such records over to the officer authorized to take this deposition
so that photographic reproductions of the same may be made and attached to said deposition.
Page 1 of 14
Respectfully submitted,
{SL Sarah Dika
SARAH DIKA
State Bar No. 24131845
arah@fuentesfirm.com
The Fuentes Firm, P.C.
701 Commerce St, Sth Floor
Dallas, TX 75202
Telephone: (281) 378-7640
ATTORNEY FOR DEFENDANTS
PRACTICAL CARGO SOLUTIONS AND
GARY DALE SR.
CERTIFICATE OF SERVICE
Pursuant to the Texas Rules of Civil Procedure, a true and correct copy of the foregoing
has been served upon all counsel of record on February 6, 2024.
{s/ Sarah Dika
SARAH DIKA
Page 2 of 14
CAUSE NO. DC-23-03551
KASSANDRA WHITE AND IN THE DISTRICT COURT OF
BARBARA AGBANYIM
Plaintiffs),
DALLAS COUNTY, TEXAS
PRACTICAL CARGO
SOLUTIONS, ET AL 134TH JUDICIAL DISTRICT
Defendant(s).
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Designated Representative of: Baylor Scott & White
Type of Records: Any and all documents and tangible items described in Exhibit A as reflected in
the Subpoena Duces Tecum served to Baylor Scott & White.
Identification of Witness
1 Please state the name, address, telephone number, employer and capacity/job title of all persons
answering these questions or helping you to answer on behalf of Baylor Scott & White.
ANSWER:
2. Please state your position and/or job title.
ANSWER:
If you require additional space, please continue on separate page
Records Authentication
3. Have you received a subpoena for the production of the documents referenced above?
ANSWER:
4. Do you have possession, custody, control of, or access to the documents or tangible items
requested? If not, please identify who does, for each item or tangible thing, by name, job title
and address.
ANSWER:
Page 3 of 14
5. Are you authorized to produce and testify as to these records on behalf of Baylor Scott &
White?
ANSWER:
6. Were the aforementioned records made in the regular course of business of your employer?
ANSWER:
7. Did a person with knowledge of the act, transaction, event, condition, opinion, or diagnosis
recorded make the record or transmit information thereof to be included in the record?
ANSWER:
8. Was it in the regular course of business of the above-listed for a person with knowledge of the
act, event, condition, opinion, or diagnosis recorded to make the record or to transmit
information thereof to be included in the record?
ANSWER:
9. Were the records produced herewith made at the time or shortly after the time of the
transactions recorded?
ANSWER:
10. Were these records kept as described in the preceding questions?
ANSWER:
11. Does the source of the information, and the method and circumstance of its preparation,
establish the trustworthiness of the records?
ANSWER:
12. Please provide true and correct copies of the original records requested, or provide originals
for photocopying at a date and time prior to the scheduled deposition. If you have not provided
these records, please state why not.
ANSWER:
13. Are there any documents or tangible items described in Exhibit A that you have NOT provided
to the notary public taking your deposition?
ANSWER:
Page 4 of 14
14. Please describe all documents and tangible items described in Exhibit A that you have not
provided, including where they are located, what they are and contain, and who has possession
of them, and explain why you have NOT provided them.
ANSWER: _
15. If you were instructed by any employee, officer, representative or attorney Baylor Scott &
White NOT to produce any documents or tangible items described in ExhibitA, please identify
the employee, officer, representative or attorney that so instructed you, including their full
name, position, company, and telephone number.
ANSWER: _ __ __ _ oo __
16. If you contend that any of the materials requested in Exhibit A are not in the possession,
custody or control of Baylor Scott & White, please identify each such item by description and
provide the complete name, address and phone number of the individual or entity that has
possession, custody or control of that item.
ANSWER:
Bills and Charges for Kassandra White
17. (a-bbbb). Please complete the chart below by writing the maximum allowed contractual rate
or range of rates in dollars and cents for each payor listed for the CPT/procedure
codes/procedure description given between 12/16/2021 to the present (please note, you must
answer these questions regardless of whether Kassandra White’s bills were submitted to any
insurance provider).
United
BCBS Aetna Cigna Humana
Healthcare
fa) Ib) lc) ld) e)
63700001
1g) Ih) i) i)
J1100
Ik) 1) m) In) 0)
J2270
Page 5 of 14
Ip) la) Ir) s) 0
J1885
lu) Vv) w) x) ly)
J2405
iz) jaa) \bb) lec) dd)
30700018
lee) ff) Ise) Inh) ii)
30000396
kk) I) Imm) man)
30000005
loo) IPP) aq) itr) ss)
30100866
tt) hau) ww) ww) kx)
30500006
yy) Iz) laa) bbb) ‘ccc)
35200010
lddd) lee) fff) legge) hhh)
999G1004
itty kkk) I) mmm)
63700001
Innn) looo) PPP) aaa) it)
45000412
Page 6 of 14
Iss) et) uuu) vv) www)
45000411
Ikxx) yyy) lzzz) laaaa) ‘bbbb)
45000429
18. Please identify each document, source, or person(s) you consulted, reviewed, or referred to in
providing the information contained in your response to Question 17.
ANSWER:
19. Have any amount of the charges for services rendered to Kassandra White during the period
from 12/16/2021 to the present been_submitted for payment to private insurance or any person
or entity other than Kassandra White?
ANSWER:
20. If your answer to question No. 19 is “No” please state the reason that Kassandra White’s bills
ere not submitted for payment to private insurance or any person or entity.
ANSWER:
21. Was Baylor Scott & White provided with a Letter of Protection, Notice of Responsible Party,
or Letter of Guarantee for health care charges for serviced rendered to Kassandra White from
12/16/2021 to the present?
ANSWER:
22. If your answer to the previous question is “yes” please state the name and address of the
individual or entity who provided such document(s).
ANSWER:
23. Please fill in the following blanks with the requested information concerning medical treatment
provided to Kassandra White from 12/16/2021 to the present date:
A. Total amount for all medical charges billed:
ANSWER:
B. First date any such charges were submitted to any private insurer:
ANSWER:
Page 7 of 14
C. Total amount paid by private insurer(s):
ANSWER:
D. Total amount paid by Medicare/Medicaid:
ANSWER:
E. Total amount paid by any factoring or financing company:
ANSWER:
F. Total amount paid by Kassandra White:
ANSWER:
G. Total amount paid by Kassandra White’s attorney:
ANSWER:
H. Total amount adjusted down, written off, or charged off:
ANSWER:
I Total amount still owed and BY WHOM:
ANSWER:
24. Does Baylor Scott & White have a cash payment option?
ANSWER:
25. If Baylor Scott & White has a cash payment option, please provide the rate(s) Baylor Scott &
White would charge under its cash payment option for each service or item provided to
Kassandra White between 12/16/2021 to the present for which you have billed or charged
(please note, you must answer this question regardless of whether Kassandra White was offered
a cash payment option):
ANSWER:
26. What is the legal name for the entity doing business as Baylor Scott & White?
ANSWER:
27. Does Baylor Scott & White accept Medicare-approved payment amounts?
Page 8 of 14
ANSWER:
28. Does Baylor Scott & White contract with United Healthcare and accept United Healthcare
reimbursement rates?
ANSWER:
29. Does Baylor Scott & White contract with Cigna insurance and accept Cigna reimbursement
rates?
ANSWER:
30. Does Baylor Scott & White contract with Blue Cross Blue Shield insurance and accept Blue
Cross Blue Shield reimbursement rates?
ANSWER:
31. Does Baylor Scott & White contract with Aetna and accept Aetna reimbursement rates?
ANSWER:
32. Does Baylor Scott & White contract with Humana and Accept Humana reimbursement rates?
ANSWER:
33. Does Baylor Scott & White accept Texas Workers’ Compensation reimbursement rates?
ANSWER:
34. Approximately what percentage Baylor Scott & White patients utilize some form of
insurance, whether governmental or private, to pay for the services provided by Baylor Scott
& White? Are all of those services reimbursed at less than the billed amount?
ANSWER:
35. Is ita common practice for Baylor Scott & White to accept less than the amount Baylor Scott
& White bills for the services it provides?
ANSWER:
36. In cases such as this where the patient is involved in litigation and Baylor Scott & White was
not paid until after the lawsuit is resolved, does Baylor Scott & White typically accept less
than the amount Baylor Scott & White billed for the services it provided?
Page 9 of 14
ANSWER:
Medical Factoring
37. Does Baylor Scott & White have any agreements, contracts, or arrangements with any third-
party financing, medical factoring, or medical funding company relating to the sale or
assignment of any medical claim submitted or medical bill created, for the medical treatment
provided to Kassandra White from 12/16/2021 to the present?
ANSWER:
38. Has Baylor Scott & White received any payments from any third-party financing, medical
factoring, or medical funding company relating to the medical treatment and services provided
to Kassandra White from 12/16/2021 to the present?
ANSWER:
39. Has Kassandra White or Brennan Clay provided documentation or correspondence to Baylor
Scott & White from a medical funding company, medical factoring company, or related to
third-party financing for the medical treatment and services provided to Kassandra White from
12/16/2021 to the present?
ANSWER:
40. If the answers to any of the preceding three questions are yes, please provide true and correct
copies of the original records as requested in the subpoena attached hereto as an exhibit, or
provide originals for photocopying at a date and time prior to the scheduled deposition. If you
have not provided these records, please state why not.
ANSWER:
41. If you are not able or not authorized to answer any of the questions above, please state which
questions you are unable to answer and provide the full name, title, business address, and phone
number of the person able or authorized to provide answers on behalf of Baylor Scott & White
to the questions identified.
ANSWER:
WITNESS(ES)
Page 10 of 14
Before me, the undersigned authority, on this day personally appeared
, known to me to be the person or persons whose name subscribed to the foregoing instrument in
the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers
to the foregoing questions are true and correct and that the records attached hereto are exact
duplicates of the original records.
SWORN TO AND SUBSCRIBED before me this day of .20
NOTARY PUBLIC
Page 11 of 14
EXHIBIT A
The subpoenaed documents described below are related to the following described patient:
Patient Name: Kassandra White
Date of Birth: 7/23/1973
Address: 9620 Windridge Way, Dallas, TX 7521
Social Security No: XXX-XX-6977
All Medical records, Billing records, and Accounting records reflecting treatment, charges
billed, amounts paid, and adjustments, reductions or write-offs applied for medical services
provided to Kassandra White by Baylor Scott & White from 12/16/2011 to the present.
All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x-
ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes
any and all MRI films on CD and/or USB); all radiology reports, including but not limited to
x-ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related
documents.
All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services
provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present,
including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed
care agreements, and chargemaster rates applicable to parties paying in cash.
All documents reflecting any insurance information provided by or on behalf of Kassandra
White to Baylor Scott & White in connection with medical services provided to Kassandra
White from 12/16/2021 to the present, including but limited to copies of any insurance cards
obtained, intake or admission forms providing any insurance information that would be
available to cover said medical services, and any correspondence from any insurer or employer
of Kassandra White identifying, denying or accepting coverage for said medical expenses.
All contracts and agreements between Baylor Scott & White and any of the following, or any
of their affiliates or agents, relating to or containing any contractual rates applicable to the
medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to
the present, including but not limited to any rate agreements, rate sheets, managed care
agreements, and chargemaster rates specific to each of the following:
Blue Cross Blue Shield,
United Healthcare,
Aetna,
Cigna,
Humana, and
any other insuring provider.
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Kassandra White the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
Page 12 of 14
whether any bills or charges for medical services provided to Kassandra White were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Kassandra White or their attorney relating to charges
and bills for medical services provided to Kassandra White from 12/16/2021 to the present,
including but not limited to any letters of protection, notices of responsible third party, letters
of guarantee, any correspondence relating to insurance, and any correspondence requesting
that charges be or not be submitted to an insurance provider.
All documents related to or concerning any claims submitted to any private insurer for charges
and bills for medical services provided to Kassandra White from 12/16/2021 to the present,
including but not limited to any claim forms, substantiating documents, acceptances or denials
from any private insurer, and any correspondence to any private insurer regarding a claim for
payment for said medical services.
All contracts and agreements between Baylor Scott & White any third-party financing,
medical factoring, or medical funding company relating to the sale or assignment of any
medical claim submitted or medical bill created, for the medical treatment provided Kassandra
White from 12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual, or
business relationship between Baylor Scott & White any third-party financing, medical
factoring, or medical funding company relating to any diagnosis or treatment given in
connection to Kassandra White from 12/16/2021 to the present.
10 All documents reflecting any payments made to or received from any third-party financing,
medical factoring, or medical funding company relating to the medical treatment provided to
Kassandra White from 12/16/2021 to the present.
11 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical diagnoses or treatment provided to Kassandra White from
12/16/2021 to the present.
12 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any contracts or agreements made in connection with the medical
treatment provided to Kassandra White from 12/16/2021 to the present.
13 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
company relating to any medical claim submitted or medical bill created in connection with
the medical treatment provided to Kassandra White from 12/16/2021 to the present.
14 All correspondence between Baylor Scott & White including any of its agents, employees,
principals, and officers, and any third-party financing, medical factoring, or medical funding
Page 13 of 14
company relating to any medical claim submitted or medical bill created in connection with
the medical treatment provided to Kassandra White from 12/16/2021 to the present.
15 All communications between Kassandra White and Baylor Scott & White including but not
limited to any correspondence, emails, text messages, telephone messages, visual voicemail or
internal notifications of pending voice messages, phone logs of calls or records of
conversations, and doctors or nurses’ notes and referrals.
16 All intake documents, history forms, patient questionnaires, intake forms, financial
disclosures, office records, inpatient and/or outpatient records relating to Kassandra White.
17 All documents related to how Kassandra White was referred to Baylor Scott & White,
including any referral emails or web forms.
18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments
potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome
of this litigation.
19 The complete contents of Baylor Scott & White’s Electronic Health Records (EHR) or
Electronic Medical Records (EMR), or any other such software relating to Kassandra White,
including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages,
Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab,
Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit
Log Reports, and Billable Submissions.
20 All marketing materials distributed to any member of Kassandra White’s present or past legal
team within the last three years.
21 All internal emails, chat room logs, text messages or other communications in any way related
to Kassandra White, their lawsuit, or their bills.
22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including
but not limited to Brennan Clay at Witherite Law Group.
Page 14 of 14
Preview
FILED 3/12/2024 3:44 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC-23-03551 KASSANDRA WHITE AND IN THE DISTRICT COURT OF BARBARA AGBANYIM Plaintiff(s), DALLAS COUNTY, TEXAS PRACTICAL CARGO SOLUTIONS, et al 134TH JUDICIAL DISTRICT Defendant(s). DEFENDANTS’ NOTICE OF SUBPOENA TO NON-PARTY BAYLOR SCOTT & WHITE TO Baylor Scott & White, by and through its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, 211 E. 7" Street, Suite 620, Austin, Texas 78701. TO Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246. TO Plaintiff, Kassandra White, by and through their attorney of record, Brennan Clay, Witherite Law Group, 10440 N. Central Expy, Suite 400, Dallas, TX 75231. PLEASE TAKE NOTICE that, under Texas Rules of Civil Procedure 205 and 176.6(c), Defendants Practical Cargo Solutions and Gary Dale Sr. intends to subpoena from Baylor Scott & White the documents described in the attached Subpoena. The documents shall be produced for inspection and copying on or before the expiration of twenty (20) days after the date of service at 10:00 a.m., at Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246, or at such earlier time as may be ordered by this Court. Page 1 of 7 Respectfully submitted, {sf Sarah Dika SARAH DIKA State Bar No. 24131845 arah@fuentesfirm.com The Fuentes Firm, P.C. 701 Commerce St, 5th Floor Dallas, TX 75202 Telephone: (281) 378-7640 ATTORNEY FOR DEFENDANTS PRACTICAL CARGO SOLUTIONS AND GARY DALE SR. CERTIFICATE OF SERVICE Pursuant to the Texas Rules of Civil Procedure, a true and correct copy of the foregoing has been served upon all counsel of record on February 6, 2024. sf. Sarah Dika SARAH DIKA Page 2 of 7 CAUSE NO. DC-23-03551 KASSANDRA WHITE AND IN THE DISTRICT COURT OF BARBARA AGBANYIM Plaintiff(s), DALLAS COUNTY, TEXAS PRACTICAL CARGO SOLUTIONS, et al 134TH JUDICIAL DISTRICT Defendant(s). SUBPOENA TO NON-PARTY BAYLOR SCOTT & WHITE THE STATE OF TEXAS § § SUBPOENA § WITNESS: BAYLOR SCOTT & WHITE YOU ARE HEREBY COMMANDED TO PRODUCE ANY AND ALL DOCUMENTS AND TANGIBLE ITEMS DESCRIBED ON EXHIBIT “A” ATTACHED HERETO. TO PRODUCE AND PERMIT DATE: 20-days after service INSPECTION AND COPYING OF TIME: 10:00 AM DESIGNATED DOCUMENTS OR PLACE: Baylor Scott & White TANGIBLE THINGS IN THE 3500 Gaston Ave POSSESSION, CUSTODY, OR Dallas, TX 75246 CONTROL: This subpoena was issued at the request of Defendants Practical Cargo Solutions and Gary Dale Sr., whose attorney of record is: Sarah Dika State Bar No. 24131845 The Fuentes Firm, P.C. 5507 Louetta Road, Suite A Spring, Texas 77379 Telephone: (281) 378-7640 CONTEMPT: FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA ISSUED OR A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE OR CONFINEMENT OR BOTH. Tex. R. Civ. P. 176.8(a). Page 3 of 7 Issued on February 6, 2024. {SL Sarah Dika SARAH DIKA State Bar No. 24131845 arah@fuentesfirm.com The Fuentes Firm, P.C. 701 Commerce St, Sth Floor Dallas, TX 75202 Telephone: (281) 378-7640 ATTORNEY FOR DEFENDANTS PRACTICAL CARGO SOLUTIONS AND GARY DALE SR. Page 4 of 7 EXHIBIT A The subpoenaed documents described below are related to the following described patient: Patient Name: Kassandra White Date of Birth: 7/23/1973 Address: 9620 Windridge Way, Dallas, TX 7521 Social Security No: XXX-XX-6977 All Medical records, Billing records, and Accounting records reflecting treatment, charges billed, amounts paid, and adjustments, reductions or write-offs applied for medical services provided to Kassandra White by Baylor Scott & White from 12/16/2011 to the present. All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x- ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes any and all MRI films on CD and/or USB); all radiology reports, including but not limited to x- ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related documents. All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed care agreements, and chargemaster rates applicable to parties paying in cash. All documents reflecting any insurance information provided by or on behalf of Kassandra White to Baylor Scott & White in connection with medical services provided to Kassandra White from 12/16/2021 to the present, including but limited to copies of any insurance cards obtained, intake or admission forms providing any insurance information that would be available to cover said medical services, and any correspondence from any insurer or employer of Kassandra White identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Baylor Scott & White and any of the following, or any of their affiliates or agents, relating to or containing any contractual rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate agreements, rate sheets, managed care agreements, and chargemaster rates specific to each of the following: Blue Cross Blue Shield, United Healthcare, Aetna, Cigna, Humana, and any other insuring provider. This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Kassandra White the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of Page 5 of 7 whether any bills or charges for medical services provided to Kassandra White were actually submitted to any insurance carrier for payment. All written correspondence to or from Kassandra White or their attorney relating to charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any letters of protection, notices of responsible third party, letters of guarantee, any correspondence relating to insurance, and any correspondence requesting that charges be or not be submitted to an insurance provider. All documents related to or concerning any claims submitted to any private insurer for charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any claim forms, substantiating documents, acceptances or denials from any private insurer, and any correspondence to any private insurer regarding a claim for payment for said medical services. All contracts and agreements between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to the sale or assignment of any medical claim submitted or medical bill created, for the medical treatment provided Kassandra White from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual or business relationship between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Kassandra White from 12/16/2021 to the present. 10 All documents reflecting any payments made to or received from any third-party financing, medical factoring, or medical funding company relating to the medical treatment provided to Kassandra White from 12/16/2021 to the present. 11 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical diagnoses or treatment provided to Kassandra White from 12/16/2021 to the present. 12 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any contracts or agreements made in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 13 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 14 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding Page 6 of 7 company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 15 All communications between Kassandra White and Baylor Scott & White including but not limited to any correspondence, emails, text messages, telephone messages, visual voicemail or internal notifications of pending voice messages, phone logs of calls or records of conversations, and doctors or nurses’ notes and referrals. 16 All intake documents, history forms, patient questionnaires, intake forms, financial disclosures, office records, inpatient and/or outpatient records relating to Kassandra White. 17 All documents related to how Kassandra White was referred to Baylor Scott & White, including any referral emails or web forms. 18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome of this litigation. 19 The complete contents of Baylor Scott & White’s Electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Kassandra White, including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages, Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab, Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit Log Reports, and Billable Submissions. 20 All marketing materials distributed to any member of Kassandra White’s present or past legal team within the last three years. 21 All internal emails, chat room logs, text messages or other communications in any way related to Kassandra White, their lawsuit, or their bills. 22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including but not limited to Brennan Clay at Witherite Law Group. Page 7 of 7 CAUSE NO. DC-23-03551 KASSANDRA WHITE AND IN THE DISTRICT COURT OF BARBARA AGBANYIM Plaintiff(s), DALLAS COUNTY, TEXAS PRACTICAL CARGO SOLUTIONS, et al 134TH JUDICIAL DISTRICT Defendant(s). SUBPOENA TO NON-PARTY BAYLOR SCOTT & WHITE THE STATE OF TEXAS § § SUBPOENA § WITNESS: BAYLOR SCOTT & WHITE YOU ARE HEREBY COMMANDED TO PRODUCE ANY AND ALL DOCUMENTS AND TANGIBLE ITEMS DESCRIBED ON EXHIBIT “A” ATTACHED HERETO. TO PRODUCE AND PERMIT DATE: 20-days after service INSPECTION AND COPYING OF TIME: 10:00 AM DESIGNATED DOCUMENTS OR PLACE: Baylor Scott & White TANGIBLE THINGS IN THE 3500 Gaston Ave POSSESSION, CUSTODY, OR Dallas, TX 75246 CONTROL: This subpoena was issued at the request of Defendants Practical Cargo Solutions and Gary Dale Sr., whose attorney of record is: Sarah Dika State Bar No. 24131845 The Fuentes Firm, P.C. 5507 Louetta Road, Suite A Spring, Texas 77379 Telephone: (281) 378-7640 CONTEMPT: FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA ISSUED OR A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE OR CONFINEMENT OR BOTH. Tex. R. Civ. P. 176.8(a). Page | of 6 Issued on February 6, 2024. {SL Sarah Dika SARAH DIKA State Bar No. 24131845 arah@fuentesfirm.com The Fuentes Firm, P.C. 701 Commerce St, Sth Floor Dallas, TX 75202 Telephone: (281) 378-7640 ATTORNEY FOR DEFENDANTS PRACTICAL CARGO SOLUTIONS AND GARY DALE SR. Page 2 of 6 EXHIBIT A The subpoenaed documents described below are related to the following described patient: Patient Name: Kassandra White Date of Birth: 7/23/1973 Address: 9620 Windridge Way, Dallas, TX 7521 Social Security No: XXX-XX-6977 All Medical records, Billing records, and Accounting records reflecting treatment, charges billed, amounts paid, and adjustments, reductions or write-offs applied for medical services provided to Kassandra White by Baylor Scott & White from 12/16/2011 to the present. All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x- ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes any and all MRI films on CD and/or USB); all radiology reports, including but not limited to x- ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related documents. All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed care agreements, and chargemaster rates applicable to parties paying in cash. All documents reflecting any insurance information provided by or on behalf of Kassandra White to Baylor Scott & White in connection with medical services provided to Kassandra White from 12/16/2021 to the present, including but limited to copies of any insurance cards obtained, intake or admission forms providing any insurance information that would be available to cover said medical services, and any correspondence from any insurer or employer of Kassandra White identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Baylor Scott & White and any of the following, or any of their affiliates or agents, relating to or containing any contractual rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate agreements, rate sheets, managed care agreements, and chargemaster rates specific to each of the following: Blue Cross Blue Shield, United Healthcare, Aetna, Cigna, Humana, and any other insuring provider. This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Kassandra White the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of Page 3 of 6 whether any bills or charges for medical services provided to Kassandra White were actually submitted to any insurance carrier for payment. All written correspondence to or from Kassandra White or their attorney relating to charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any letters of protection, notices of responsible third party, letters of guarantee, any correspondence relating to insurance, and any correspondence requesting that charges be or not be submitted to an insurance provider. All documents related to or concerning any claims submitted to any private insurer for charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any claim forms, substantiating documents, acceptances or denials from any private insurer, and any correspondence to any private insurer regarding a claim for payment for said medical services. All contracts and agreements between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to the sale or assignment of any medical claim submitted or medical bill created, for the medical treatment provided Kassandra White from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual or business relationship between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Kassandra White from 12/16/2021 to the present. 10 All documents reflecting any payments made to or received from any third-party financing, medical factoring, or medical funding company relating to the medical treatment provided to Kassandra White from 12/16/2021 to the present. 11 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical diagnoses or treatment provided to Kassandra White from 12/16/2021 to the present. 12 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any contracts or agreements made in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 13 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 14 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding Page 4 of 6 company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 15 All communications between Kassandra White and Baylor Scott & White including but not limited to any correspondence, emails, text messages, telephone messages, visual voicemail or internal notifications of pending voice messages, phone logs of calls or records of conversations, and doctors or nurses’ notes and referrals. 16 All intake documents, history forms, patient questionnaires, intake forms, financial disclosures, office records, inpatient and/or outpatient records relating to Kassandra White. 17 All documents related to how Kassandra White was referred to Baylor Scott & White, including any referral emails or web forms. 18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome of this litigation. 19 The complete contents of Baylor Scott & White’s electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Kassandra White, including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages, Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab, Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit Log Reports, and Billable Submissions. 20 All marketing materials distributed to any member of Kassandra White’s present or past legal team within the last three years. 21 All internal emails, chat room logs, text messages or other communications in any way related to Kassandra White, their lawsuit, or their bills. 22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including but not limited to Brennan Clay at Witherite Law Group. Page 5 of 6 PROOF OF SERVICE Via Personal Service: Baylor Scott & White by and through its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company 211 E. 7th Street, Suite 620 Austin, Texas 78701 Page 6 of 6 CAUSE NO. DC-23-03551 KASSANDRA WHITE AND IN THE DISTRICT COURT OF BARBARA AGBANYIM Plaintiff(s), DALLAS COUNTY, TEXAS PRACTICAL CARGO SOLUTIONS, ET AL 134TH JUDICIAL DISTRICT Defendant(s). NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS TO Baylor Scott & White, by and through its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, 211 E. 7" Street, Suite 620, Austin, Texas 78701. TO Baylor Scott & White, 3500 Gaston Ave., Dallas, TX 75246. TO Plaintiff, Kassandra White, by and through their attorney of record, Brennan Clay, Witherite Law Group, 10440 N. Central Expy, Suite 400, Dallas, TX 75231. TAKE NOTICE THAT twenty days after service of a copy hereof with attached questions, a deposition by written questions will be taken of Baylor Scott & White, on the matters described below in the DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS which are attached hereto. This examination is requested at the address listed below: BAYLOR SCOTT & WHITE 3500 GASTON AVE DALLAS, TX 75246 Pursuant to Texas Rules of Civil Procedure 176.6(b), the named organization must designate one or more officers, directors, or managing agents, or designate other persons to testify on its behalf; and it may set out the matters on which each person designated will testify. The persons designated must testify about information known or reasonably available to the organization. This deposition with attached questions may be used as evidence upon the trial of the above-styled and numbered cause pending in the above-named court. Notice is further given that request is hereby made as authorized under Texas Rules of Civil Procedure 176 and 200 to the officer taking this deposition to issue a subpoena and cause it to be served on the witness to bring and produce for inspection and photocopying a true and correct copy of records described in the attached Written Questions and to turn all such records over to the officer authorized to take this deposition so that photographic reproductions of the same may be made and attached to said deposition. Page 1 of 14 Respectfully submitted, {SL Sarah Dika SARAH DIKA State Bar No. 24131845 arah@fuentesfirm.com The Fuentes Firm, P.C. 701 Commerce St, Sth Floor Dallas, TX 75202 Telephone: (281) 378-7640 ATTORNEY FOR DEFENDANTS PRACTICAL CARGO SOLUTIONS AND GARY DALE SR. CERTIFICATE OF SERVICE Pursuant to the Texas Rules of Civil Procedure, a true and correct copy of the foregoing has been served upon all counsel of record on February 6, 2024. {s/ Sarah Dika SARAH DIKA Page 2 of 14 CAUSE NO. DC-23-03551 KASSANDRA WHITE AND IN THE DISTRICT COURT OF BARBARA AGBANYIM Plaintiffs), DALLAS COUNTY, TEXAS PRACTICAL CARGO SOLUTIONS, ET AL 134TH JUDICIAL DISTRICT Defendant(s). DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Designated Representative of: Baylor Scott & White Type of Records: Any and all documents and tangible items described in Exhibit A as reflected in the Subpoena Duces Tecum served to Baylor Scott & White. Identification of Witness 1 Please state the name, address, telephone number, employer and capacity/job title of all persons answering these questions or helping you to answer on behalf of Baylor Scott & White. ANSWER: 2. Please state your position and/or job title. ANSWER: If you require additional space, please continue on separate page Records Authentication 3. Have you received a subpoena for the production of the documents referenced above? ANSWER: 4. Do you have possession, custody, control of, or access to the documents or tangible items requested? If not, please identify who does, for each item or tangible thing, by name, job title and address. ANSWER: Page 3 of 14 5. Are you authorized to produce and testify as to these records on behalf of Baylor Scott & White? ANSWER: 6. Were the aforementioned records made in the regular course of business of your employer? ANSWER: 7. Did a person with knowledge of the act, transaction, event, condition, opinion, or diagnosis recorded make the record or transmit information thereof to be included in the record? ANSWER: 8. Was it in the regular course of business of the above-listed for a person with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in the record? ANSWER: 9. Were the records produced herewith made at the time or shortly after the time of the transactions recorded? ANSWER: 10. Were these records kept as described in the preceding questions? ANSWER: 11. Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER: 12. Please provide true and correct copies of the original records requested, or provide originals for photocopying at a date and time prior to the scheduled deposition. If you have not provided these records, please state why not. ANSWER: 13. Are there any documents or tangible items described in Exhibit A that you have NOT provided to the notary public taking your deposition? ANSWER: Page 4 of 14 14. Please describe all documents and tangible items described in Exhibit A that you have not provided, including where they are located, what they are and contain, and who has possession of them, and explain why you have NOT provided them. ANSWER: _ 15. If you were instructed by any employee, officer, representative or attorney Baylor Scott & White NOT to produce any documents or tangible items described in ExhibitA, please identify the employee, officer, representative or attorney that so instructed you, including their full name, position, company, and telephone number. ANSWER: _ __ __ _ oo __ 16. If you contend that any of the materials requested in Exhibit A are not in the possession, custody or control of Baylor Scott & White, please identify each such item by description and provide the complete name, address and phone number of the individual or entity that has possession, custody or control of that item. ANSWER: Bills and Charges for Kassandra White 17. (a-bbbb). Please complete the chart below by writing the maximum allowed contractual rate or range of rates in dollars and cents for each payor listed for the CPT/procedure codes/procedure description given between 12/16/2021 to the present (please note, you must answer these questions regardless of whether Kassandra White’s bills were submitted to any insurance provider). United BCBS Aetna Cigna Humana Healthcare fa) Ib) lc) ld) e) 63700001 1g) Ih) i) i) J1100 Ik) 1) m) In) 0) J2270 Page 5 of 14 Ip) la) Ir) s) 0 J1885 lu) Vv) w) x) ly) J2405 iz) jaa) \bb) lec) dd) 30700018 lee) ff) Ise) Inh) ii) 30000396 kk) I) Imm) man) 30000005 loo) IPP) aq) itr) ss) 30100866 tt) hau) ww) ww) kx) 30500006 yy) Iz) laa) bbb) ‘ccc) 35200010 lddd) lee) fff) legge) hhh) 999G1004 itty kkk) I) mmm) 63700001 Innn) looo) PPP) aaa) it) 45000412 Page 6 of 14 Iss) et) uuu) vv) www) 45000411 Ikxx) yyy) lzzz) laaaa) ‘bbbb) 45000429 18. Please identify each document, source, or person(s) you consulted, reviewed, or referred to in providing the information contained in your response to Question 17. ANSWER: 19. Have any amount of the charges for services rendered to Kassandra White during the period from 12/16/2021 to the present been_submitted for payment to private insurance or any person or entity other than Kassandra White? ANSWER: 20. If your answer to question No. 19 is “No” please state the reason that Kassandra White’s bills ere not submitted for payment to private insurance or any person or entity. ANSWER: 21. Was Baylor Scott & White provided with a Letter of Protection, Notice of Responsible Party, or Letter of Guarantee for health care charges for serviced rendered to Kassandra White from 12/16/2021 to the present? ANSWER: 22. If your answer to the previous question is “yes” please state the name and address of the individual or entity who provided such document(s). ANSWER: 23. Please fill in the following blanks with the requested information concerning medical treatment provided to Kassandra White from 12/16/2021 to the present date: A. Total amount for all medical charges billed: ANSWER: B. First date any such charges were submitted to any private insurer: ANSWER: Page 7 of 14 C. Total amount paid by private insurer(s): ANSWER: D. Total amount paid by Medicare/Medicaid: ANSWER: E. Total amount paid by any factoring or financing company: ANSWER: F. Total amount paid by Kassandra White: ANSWER: G. Total amount paid by Kassandra White’s attorney: ANSWER: H. Total amount adjusted down, written off, or charged off: ANSWER: I Total amount still owed and BY WHOM: ANSWER: 24. Does Baylor Scott & White have a cash payment option? ANSWER: 25. If Baylor Scott & White has a cash payment option, please provide the rate(s) Baylor Scott & White would charge under its cash payment option for each service or item provided to Kassandra White between 12/16/2021 to the present for which you have billed or charged (please note, you must answer this question regardless of whether Kassandra White was offered a cash payment option): ANSWER: 26. What is the legal name for the entity doing business as Baylor Scott & White? ANSWER: 27. Does Baylor Scott & White accept Medicare-approved payment amounts? Page 8 of 14 ANSWER: 28. Does Baylor Scott & White contract with United Healthcare and accept United Healthcare reimbursement rates? ANSWER: 29. Does Baylor Scott & White contract with Cigna insurance and accept Cigna reimbursement rates? ANSWER: 30. Does Baylor Scott & White contract with Blue Cross Blue Shield insurance and accept Blue Cross Blue Shield reimbursement rates? ANSWER: 31. Does Baylor Scott & White contract with Aetna and accept Aetna reimbursement rates? ANSWER: 32. Does Baylor Scott & White contract with Humana and Accept Humana reimbursement rates? ANSWER: 33. Does Baylor Scott & White accept Texas Workers’ Compensation reimbursement rates? ANSWER: 34. Approximately what percentage Baylor Scott & White patients utilize some form of insurance, whether governmental or private, to pay for the services provided by Baylor Scott & White? Are all of those services reimbursed at less than the billed amount? ANSWER: 35. Is ita common practice for Baylor Scott & White to accept less than the amount Baylor Scott & White bills for the services it provides? ANSWER: 36. In cases such as this where the patient is involved in litigation and Baylor Scott & White was not paid until after the lawsuit is resolved, does Baylor Scott & White typically accept less than the amount Baylor Scott & White billed for the services it provided? Page 9 of 14 ANSWER: Medical Factoring 37. Does Baylor Scott & White have any agreements, contracts, or arrangements with any third- party financing, medical factoring, or medical funding company relating to the sale or assignment of any medical claim submitted or medical bill created, for the medical treatment provided to Kassandra White from 12/16/2021 to the present? ANSWER: 38. Has Baylor Scott & White received any payments from any third-party financing, medical factoring, or medical funding company relating to the medical treatment and services provided to Kassandra White from 12/16/2021 to the present? ANSWER: 39. Has Kassandra White or Brennan Clay provided documentation or correspondence to Baylor Scott & White from a medical funding company, medical factoring company, or related to third-party financing for the medical treatment and services provided to Kassandra White from 12/16/2021 to the present? ANSWER: 40. If the answers to any of the preceding three questions are yes, please provide true and correct copies of the original records as requested in the subpoena attached hereto as an exhibit, or provide originals for photocopying at a date and time prior to the scheduled deposition. If you have not provided these records, please state why not. ANSWER: 41. If you are not able or not authorized to answer any of the questions above, please state which questions you are unable to answer and provide the full name, title, business address, and phone number of the person able or authorized to provide answers on behalf of Baylor Scott & White to the questions identified. ANSWER: WITNESS(ES) Page 10 of 14 Before me, the undersigned authority, on this day personally appeared , known to me to be the person or persons whose name subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct and that the records attached hereto are exact duplicates of the original records. SWORN TO AND SUBSCRIBED before me this day of .20 NOTARY PUBLIC Page 11 of 14 EXHIBIT A The subpoenaed documents described below are related to the following described patient: Patient Name: Kassandra White Date of Birth: 7/23/1973 Address: 9620 Windridge Way, Dallas, TX 7521 Social Security No: XXX-XX-6977 All Medical records, Billing records, and Accounting records reflecting treatment, charges billed, amounts paid, and adjustments, reductions or write-offs applied for medical services provided to Kassandra White by Baylor Scott & White from 12/16/2011 to the present. All Radiology and MRI Films from 12/16/2011 to the present, including but not limited to x- ray films, MRI films, CT scans, and any other type of diagnostic imaging films (this includes any and all MRI films on CD and/or USB); all radiology reports, including but not limited to x-ray reports, MRI reports, CT Scan reports and/or ultrasound reports; and all related documents. All documents reflecting Baylor Scott & White’s cash rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate Baylor Scott & White agreements, rate sheets, managed care agreements, and chargemaster rates applicable to parties paying in cash. All documents reflecting any insurance information provided by or on behalf of Kassandra White to Baylor Scott & White in connection with medical services provided to Kassandra White from 12/16/2021 to the present, including but limited to copies of any insurance cards obtained, intake or admission forms providing any insurance information that would be available to cover said medical services, and any correspondence from any insurer or employer of Kassandra White identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Baylor Scott & White and any of the following, or any of their affiliates or agents, relating to or containing any contractual rates applicable to the medical services provided to Kassandra White by Baylor Scott & White from 12/16/2021 to the present, including but not limited to any rate agreements, rate sheets, managed care agreements, and chargemaster rates specific to each of the following: Blue Cross Blue Shield, United Healthcare, Aetna, Cigna, Humana, and any other insuring provider. This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Kassandra White the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of Page 12 of 14 whether any bills or charges for medical services provided to Kassandra White were actually submitted to any insurance carrier for payment. All written correspondence to or from Kassandra White or their attorney relating to charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any letters of protection, notices of responsible third party, letters of guarantee, any correspondence relating to insurance, and any correspondence requesting that charges be or not be submitted to an insurance provider. All documents related to or concerning any claims submitted to any private insurer for charges and bills for medical services provided to Kassandra White from 12/16/2021 to the present, including but not limited to any claim forms, substantiating documents, acceptances or denials from any private insurer, and any correspondence to any private insurer regarding a claim for payment for said medical services. All contracts and agreements between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to the sale or assignment of any medical claim submitted or medical bill created, for the medical treatment provided Kassandra White from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual, or business relationship between Baylor Scott & White any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Kassandra White from 12/16/2021 to the present. 10 All documents reflecting any payments made to or received from any third-party financing, medical factoring, or medical funding company relating to the medical treatment provided to Kassandra White from 12/16/2021 to the present. 11 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical diagnoses or treatment provided to Kassandra White from 12/16/2021 to the present. 12 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any contracts or agreements made in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 13 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 14 All correspondence between Baylor Scott & White including any of its agents, employees, principals, and officers, and any third-party financing, medical factoring, or medical funding Page 13 of 14 company relating to any medical claim submitted or medical bill created in connection with the medical treatment provided to Kassandra White from 12/16/2021 to the present. 15 All communications between Kassandra White and Baylor Scott & White including but not limited to any correspondence, emails, text messages, telephone messages, visual voicemail or internal notifications of pending voice messages, phone logs of calls or records of conversations, and doctors or nurses’ notes and referrals. 16 All intake documents, history forms, patient questionnaires, intake forms, financial disclosures, office records, inpatient and/or outpatient records relating to Kassandra White. 17 All documents related to how Kassandra White was referred to Baylor Scott & White, including any referral emails or web forms. 18 Any and all contracts, liens, assignment of rights, agreements to pay, or other legal instruments potentially giving you or anyone with Baylor Scott & White a financial interest in the outcome of this litigation. 19 The complete contents of Baylor Scott & White’s Electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Kassandra White, including, but not limited to: Patient Notes, Patient Alert Notes, Notes from Billing Tab pages, Patient Tab, Billing Tab, Guarantor Tab, Additional Tab, Insurance Tab, Contacts Tab, Appointments Tab, Financial Tab, Payment Plan Tab, Historical Data Tab, Registry Tab, Audit Log Reports, and Billable Submissions. 20 All marketing materials distributed to any member of Kassandra White’s present or past legal team within the last three years. 21 All internal emails, chat room logs, text messages or other communications in any way related to Kassandra White, their lawsuit, or their bills. 22. Any agreements between Baylor Scott & White and Kassandra White’s attorneys, including but not limited to Brennan Clay at Witherite Law Group. Page 14 of 14