Preview
FILED
3/12/2024 4:11 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
UPTOWN RADIOLOGY ASSOCIATES, PLLC
TO Uptown Radiology Associates, PLLC, by and through its registered agent, Texan
Registered Agent LLC, 5900 Balcones Drive, Suite 100, Austin, TX 78731.
TO Uptown Radiology Associates, PLLC, 1015 West Randol Mill Road, Arlington, TX 76012.
TO Plaintiff, Barbara Agbanyim, 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. intend to subpoena from Uptown
Radiology Associates, PLLC 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 Uptown Radiology Associates, PLLC, 1015 West Randol Mill
Road, Arlington, TX 76012, 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 5, 2024.
LL. 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 UPTOWN RADIOLOGY ASSOCIATES, PLLC
THE STATE OF TEXAS §
§
SUBPOENA §
WITNESS: UPTOWN RADIOLOGY ASSOCIATES, PLLC
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: Uptown Radiology Associates
TANGIBLE THINGS IN THE 1015 West Randol Mill Road
POSSESSION, CUSTODY, OR Arlington, TX 76012
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
Page 3 of 7
PUNISHED BY FINE OR CONFINEMENT OR BOTH. Tex. R. Civ.
P. 176.8(a).
Issued on February 5, 2024.
Js Sarah Dika
SARAH DIKA
State Bar No. 24131845
sarah@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.
Page 4 of 7
EXHIBIT A
The subpoenaed documents described below are related to the following described patient:
Patient Name: Barbara Agbanyim
Date of Birth: 3/8/1956
Address: 2811 Rowland Drive, Seagoville, TX 75159
Social Security No: XXX-XX-1280
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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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.
3 All documents reflecting Uptown Radiology Associates, PLLC’s cash rates applicable to the
medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC
from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology
Associates, PLLC 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 Barbara
Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services
provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage
for said medical expenses.
All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology
Associates, PLLC 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.
Page 5 of 7
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Barbara Agbanyim the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
whether any bills or charges for medical services provided to Barbara Agbanyim were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Barbara Agbanyim or their attorney relating to charges
and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual or
business relationship between Uptown Radiology Associates, PLLC any third-party
financing, medical factoring, or medical funding company relating to any diagnosis or
treatment given in connection to Barbara Agbanyim 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
Barbara Agbanyim from 12/16/2021 to the present.
11 All correspondence between Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present.
13 All correspondence between Uptown Radiology Associates, PLLC 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
Page 6 of 7
in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to
the present.
14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to
the present.
15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC
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 Barbara Agbanyim.
17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology
Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial
interest in the outcome of this litigation.
19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records
(EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara
Agbanyim, 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 Barbara Agbanyim’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 Barbara Agbanyim, their lawsuit, or their bills.
22. Any agreements between Uptown Radiology Associates, PLLC and Barbara Agbanyim’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 UPTOWN RADIOLOGY ASSOCIATES, PLLC
THE STATE OF TEXAS §
§
SUBPOENA §
WITNESS: UPTOWN RADIOLOGY ASSOCIATES, PLLC
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: Uptown Radiology Associates
TANGIBLE THINGS IN THE West Randol Mill Road
POSSESSION, CUSTODY, OR Arlington, TX 76012
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 5, 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: Barbara Agbanyim
Date of Birth: 3/8/1956
Address: 2811 Rowland Drive, Seagoville, TX 75159
Social Security No: XXX-XX-1280
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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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.
3 All documents reflecting Uptown Radiology Associates, PLLC’s cash rates applicable to the
medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC
from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology
Associates, PLLC 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 Barbara
Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services
provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage
for said medical expenses.
All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology
Associates, PLLC 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.
Page 3 of 6
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Barbara Agbanyim the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
whether any bills or charges for medical services provided to Barbara Agbanyim were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Barbara Agbanyim or their attorney relating to charges
and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual or
business relationship between Uptown Radiology Associates, PLLC any third-party
financing, medical factoring, or medical funding company relating to any diagnosis or
treatment given in connection to Barbara Agbanyim 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
Barbara Agbanyim from 12/16/2021 to the present.
11 All correspondence between Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present.
13 All correspondence between Uptown Radiology Associates, PLLC 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
Page 4 of 6
in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to
the present.
14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to
the present.
15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC
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 Barbara Agbanyim.
17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology
Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial
interest in the outcome of this litigation.
19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records
(EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara
Agbanyim, 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 Barbara Agbanyim’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 Barbara Agbanyim, their lawsuit, or their bills.
22. Any agreements between Uptown Radiology Associates, PLLC and Barbara Agbanyim’s
attorneys, including but not limited to Brennan Clay at Witherite Law Group.
Page 5 of 6
PROOF OF SERVICE
Via Personal Service:
Uptown Radiology Associates, PLLC
by and through its registered agent, Texan Registered Agent LLC
5900 Balcones Drive, Suite 100
Austin, TX 78731
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 Uptown Radiology Associates, PLLC, by and through its registered agent, Texan
Registered Agent LLC, 5900 Balcones Drive, Suite 100, Austin, TX 78731.
TO Uptown Radiology Associates, PLLC, 1015 West Randol Mill Road, Arlington, TX 76012.
TO Plaintiff, Barbara Agbanyim, 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 Uptown Radiology Associates, PLLC, 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:
UPTOWN RADIOLOGY ASSOCIATES, PLLC
1015 WEST RANDOL MILL ROAD
ARLINGTON, TX 76012
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 13
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 5, 2024.
{sf Sarah Dika
SARAH DIKA
Page 2 of 13
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: Uptown Radiology Associates, PLLC
Type of Records: Any and all documents and tangible items described in Exhibit A as reflected in
the Subpoena Duces Tecum served to Uptown Radiology Associates, PLLC.
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 Uptown Radiology
Associates, PLLC.
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.
Page 3 of 13
ANSWER:
5. Are you authorized to produce and testify as to these records on behalf of Uptown Radiology
Associates, PLLC?
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 13
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 Uptown Radiology
Associates, PLLC NOT to produce any documents or tangible items described in Exhibit A,
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 Uptown Radiology Associates, PLLC, 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 Barbara Agbanyim
17. (a-0). 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 Barbara Agbanyim’s bills were submitted to any insurance
provider).
United
BCBS Aetna Cigna Humana
Healthcare
fa) Ib) lc) ld) e)
72125
1g) Ih) i) i)
72131
Ik) 1) m) In) 0)
73221
Page 5 of 13
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 Barbara Agbanyim during the period
from 12/16/2021 to the present been submitted for payment to private insurance or any person
or entity other than Barbara Agbanyim?
ANSWER:
20. If your answer to question No. 19 is “No” please state the reason that Barbara Agbanyim’s bills
were not submitted for payment to private insurance or any person or entity.
ANSWER:
21. Was Uptown Radiology Associates, PLLC provided with a Letter of Protection, Notice of
Responsible Party, or Letter of Guarantee for health care charges for services rendered to
Barbara Agbanyim 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 Barbara Agbanyim 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:
C. Total amount paid by private insurer(s):
ANSWER:
D. Total amount paid by Medicare/Medicaid:
ANSWER:
Page 6 of 13
E. Total amount paid by any factoring or financing company
ANSWER:
F. Total amount paid by Barbara Agbanyim:
ANSWER:
G. Total amount paid by Barbara Agbanyim’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 Uptown Radiology Associates, PLLC have a cash payment option?
ANSWER:
25. If Uptown Radiology Associates, PLLC has a cash payment option, please provide the rate(s)
Uptown Radiology Associates, PLLC would charge under its cash payment option for each
service or item provided to Barbara Agbanyim between 12/16/2021 to the present for which
you have billed or charged (please note, you must answer this question regardless of whether
Barbara Agbanyim was offered a cash payment option):
ANSWER:
26. What is the legal name for the entity doing business as Uptown Radiology Associates, PLLC?
ANSWER:
27. Does Uptown Radiology Associates, PLLC accept Medicare-approved payment amounts?
ANSWER:
28. Does Uptown Radiology Associates, PLLC contract with United Healthcare and accept
United Healthcare reimbursement rates?
ANSWER:
Page 7 of 13
29. Does Uptown Radiology Associates, PLLC contract with Cigna insurance and accept Cigna
reimbursement rates?
ANSWER:
30. Does Uptown Radiology Associates, PLLC contract with Blue Cross Blue Shield insurance
and accept Blue Cross Blue Shield reimbursement rates?
ANSWER:
31. Does Uptown Radiology Associates, PLLC contract with Aetna and accept Aetna
reimbursement rates?
ANSWER:
32. Does Uptown Radiology Associates, PLLC contract with Humana and Accept Humana
reimbursement rates?
ANSWER:
33. Does Uptown Radiology Associates, PLLC accept Texas Workers’ Compensation
reimbursement rates?
ANSWER:
34. Approximately what percentage Uptown Radiology Associates, PLLC patients utilize some
form of insurance, whether governmental or private, to pay for the services provided by
Uptown Radiology Associates, PLLC? Are all of those services reimbursed at less than the
billed amount?
ANSWER:
35. Is it a common practice for Uptown Radiology Associates, PLLC to accept less than the
amount Uptown Radiology Associates, PLLC bills for the services it provides?
ANSWER:
36. In cases such as this where the patient is involved in litigation and Uptown Radiology
Associates, PLLC was not paid until after the lawsuit is resolved, does Uptown Radiology
Associates, PLLC typically accept less than the amount Uptown Radiology Associates, PLLC
billed for the services it provided?
ANSWER:
Page 8 of 13
Medical Factoring
37. Does Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present?
ANSWER:
38. Has Uptown Radiology Associates, PLLC received any payments from any third-party
financing, medical factoring, or medical funding company relating to the medical treatment
and services provided to Barbara Agbanyim from 12/16/2021 to the present?
ANSWER:
39. Has Barbara Agbanyim or provided documentation or correspondence to Uptown Radiology
Associates, PLLC from a medical funding company, medical factoring company, or related to
third-party financing for the medical treatment and services provided to Barbara Agbanyim
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 Uptown Radiology
Associates, PLLC to the questions identified.
ANSWER:
WITNESS(ES)
Page 9 of 13
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 10 of 13
EXHIBIT A
The subpoenaed documents described below are related to the following described patient:
Patient Name: Barbara Agbanyim
Date of Birth: 3/8/1956
Address: 2811 Rowland Drive, Seagoville, TX 75159
Social Security No: XXX-XX-1280
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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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 Uptown Radiology Associates, PLLC’s cash rates applicable to the
medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC
from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology
Associates, PLLC 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 Barbara
Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services
provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage
for said medical expenses.
All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology
Associates, PLLC 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.
Page 11 of 13
This request specifically seeks any contracts, agreements or rates that would have been
applicable to any medical services provided to Barbara Agbanyim the time period requested,
regardless of whether any applicable contractual rates were actually applied and regardless of
whether any bills or charges for medical services provided to Barbara Agbanyim were actually
submitted to any insurance carrier for payment.
All written correspondence to or from Barbara Agbanyim or their attorney relating to charges
and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
All documents describing, referring to, or governing the terms of any financial, contractual, or
business relationship between Uptown Radiology Associates, PLLC any third-party
financing, medical factoring, or medical funding company relating to any diagnosis or
treatment given in connection to Barbara Agbanyim 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
Barbara Agbanyim from 12/16/2021 to the present.
11 All correspondence between Uptown Radiology Associates, PLLC 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
Barbara Agbanyim from 12/16/2021 to the present.
12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present.
13 All correspondence between Uptown Radiology Associates, PLLC 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
Page 12 of 13
in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to
the present.
14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to
the present.
15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC
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 Barbara Agbanyim.
17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology
Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial
interest in the outcome of this litigation.
19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records
(EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara
Agbanyim, 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
Preview
FILED 3/12/2024 4:11 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 UPTOWN RADIOLOGY ASSOCIATES, PLLC TO Uptown Radiology Associates, PLLC, by and through its registered agent, Texan Registered Agent LLC, 5900 Balcones Drive, Suite 100, Austin, TX 78731. TO Uptown Radiology Associates, PLLC, 1015 West Randol Mill Road, Arlington, TX 76012. TO Plaintiff, Barbara Agbanyim, 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. intend to subpoena from Uptown Radiology Associates, PLLC 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 Uptown Radiology Associates, PLLC, 1015 West Randol Mill Road, Arlington, TX 76012, 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 5, 2024. LL. 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 UPTOWN RADIOLOGY ASSOCIATES, PLLC THE STATE OF TEXAS § § SUBPOENA § WITNESS: UPTOWN RADIOLOGY ASSOCIATES, PLLC 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: Uptown Radiology Associates TANGIBLE THINGS IN THE 1015 West Randol Mill Road POSSESSION, CUSTODY, OR Arlington, TX 76012 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 Page 3 of 7 PUNISHED BY FINE OR CONFINEMENT OR BOTH. Tex. R. Civ. P. 176.8(a). Issued on February 5, 2024. Js Sarah Dika SARAH DIKA State Bar No. 24131845 sarah@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. Page 4 of 7 EXHIBIT A The subpoenaed documents described below are related to the following described patient: Patient Name: Barbara Agbanyim Date of Birth: 3/8/1956 Address: 2811 Rowland Drive, Seagoville, TX 75159 Social Security No: XXX-XX-1280 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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. 3 All documents reflecting Uptown Radiology Associates, PLLC’s cash rates applicable to the medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology Associates, PLLC 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 Barbara Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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. Page 5 of 7 This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Barbara Agbanyim the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of whether any bills or charges for medical services provided to Barbara Agbanyim were actually submitted to any insurance carrier for payment. All written correspondence to or from Barbara Agbanyim or their attorney relating to charges and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual or business relationship between Uptown Radiology Associates, PLLC any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Barbara Agbanyim 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 Barbara Agbanyim from 12/16/2021 to the present. 11 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 13 All correspondence between Uptown Radiology Associates, PLLC 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 Page 6 of 7 in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to the present. 14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC 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 Barbara Agbanyim. 17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial interest in the outcome of this litigation. 19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara Agbanyim, 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 Barbara Agbanyim’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 Barbara Agbanyim, their lawsuit, or their bills. 22. Any agreements between Uptown Radiology Associates, PLLC and Barbara Agbanyim’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 UPTOWN RADIOLOGY ASSOCIATES, PLLC THE STATE OF TEXAS § § SUBPOENA § WITNESS: UPTOWN RADIOLOGY ASSOCIATES, PLLC 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: Uptown Radiology Associates TANGIBLE THINGS IN THE West Randol Mill Road POSSESSION, CUSTODY, OR Arlington, TX 76012 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 5, 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: Barbara Agbanyim Date of Birth: 3/8/1956 Address: 2811 Rowland Drive, Seagoville, TX 75159 Social Security No: XXX-XX-1280 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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. 3 All documents reflecting Uptown Radiology Associates, PLLC’s cash rates applicable to the medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology Associates, PLLC 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 Barbara Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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. Page 3 of 6 This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Barbara Agbanyim the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of whether any bills or charges for medical services provided to Barbara Agbanyim were actually submitted to any insurance carrier for payment. All written correspondence to or from Barbara Agbanyim or their attorney relating to charges and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual or business relationship between Uptown Radiology Associates, PLLC any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Barbara Agbanyim 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 Barbara Agbanyim from 12/16/2021 to the present. 11 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 13 All correspondence between Uptown Radiology Associates, PLLC 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 Page 4 of 6 in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to the present. 14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC 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 Barbara Agbanyim. 17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial interest in the outcome of this litigation. 19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara Agbanyim, 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 Barbara Agbanyim’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 Barbara Agbanyim, their lawsuit, or their bills. 22. Any agreements between Uptown Radiology Associates, PLLC and Barbara Agbanyim’s attorneys, including but not limited to Brennan Clay at Witherite Law Group. Page 5 of 6 PROOF OF SERVICE Via Personal Service: Uptown Radiology Associates, PLLC by and through its registered agent, Texan Registered Agent LLC 5900 Balcones Drive, Suite 100 Austin, TX 78731 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 Uptown Radiology Associates, PLLC, by and through its registered agent, Texan Registered Agent LLC, 5900 Balcones Drive, Suite 100, Austin, TX 78731. TO Uptown Radiology Associates, PLLC, 1015 West Randol Mill Road, Arlington, TX 76012. TO Plaintiff, Barbara Agbanyim, 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 Uptown Radiology Associates, PLLC, 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: UPTOWN RADIOLOGY ASSOCIATES, PLLC 1015 WEST RANDOL MILL ROAD ARLINGTON, TX 76012 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 13 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 5, 2024. {sf Sarah Dika SARAH DIKA Page 2 of 13 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: Uptown Radiology Associates, PLLC Type of Records: Any and all documents and tangible items described in Exhibit A as reflected in the Subpoena Duces Tecum served to Uptown Radiology Associates, PLLC. 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 Uptown Radiology Associates, PLLC. 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. Page 3 of 13 ANSWER: 5. Are you authorized to produce and testify as to these records on behalf of Uptown Radiology Associates, PLLC? 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 13 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 Uptown Radiology Associates, PLLC NOT to produce any documents or tangible items described in Exhibit A, 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 Uptown Radiology Associates, PLLC, 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 Barbara Agbanyim 17. (a-0). 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 Barbara Agbanyim’s bills were submitted to any insurance provider). United BCBS Aetna Cigna Humana Healthcare fa) Ib) lc) ld) e) 72125 1g) Ih) i) i) 72131 Ik) 1) m) In) 0) 73221 Page 5 of 13 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 Barbara Agbanyim during the period from 12/16/2021 to the present been submitted for payment to private insurance or any person or entity other than Barbara Agbanyim? ANSWER: 20. If your answer to question No. 19 is “No” please state the reason that Barbara Agbanyim’s bills were not submitted for payment to private insurance or any person or entity. ANSWER: 21. Was Uptown Radiology Associates, PLLC provided with a Letter of Protection, Notice of Responsible Party, or Letter of Guarantee for health care charges for services rendered to Barbara Agbanyim 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 Barbara Agbanyim 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: C. Total amount paid by private insurer(s): ANSWER: D. Total amount paid by Medicare/Medicaid: ANSWER: Page 6 of 13 E. Total amount paid by any factoring or financing company ANSWER: F. Total amount paid by Barbara Agbanyim: ANSWER: G. Total amount paid by Barbara Agbanyim’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 Uptown Radiology Associates, PLLC have a cash payment option? ANSWER: 25. If Uptown Radiology Associates, PLLC has a cash payment option, please provide the rate(s) Uptown Radiology Associates, PLLC would charge under its cash payment option for each service or item provided to Barbara Agbanyim between 12/16/2021 to the present for which you have billed or charged (please note, you must answer this question regardless of whether Barbara Agbanyim was offered a cash payment option): ANSWER: 26. What is the legal name for the entity doing business as Uptown Radiology Associates, PLLC? ANSWER: 27. Does Uptown Radiology Associates, PLLC accept Medicare-approved payment amounts? ANSWER: 28. Does Uptown Radiology Associates, PLLC contract with United Healthcare and accept United Healthcare reimbursement rates? ANSWER: Page 7 of 13 29. Does Uptown Radiology Associates, PLLC contract with Cigna insurance and accept Cigna reimbursement rates? ANSWER: 30. Does Uptown Radiology Associates, PLLC contract with Blue Cross Blue Shield insurance and accept Blue Cross Blue Shield reimbursement rates? ANSWER: 31. Does Uptown Radiology Associates, PLLC contract with Aetna and accept Aetna reimbursement rates? ANSWER: 32. Does Uptown Radiology Associates, PLLC contract with Humana and Accept Humana reimbursement rates? ANSWER: 33. Does Uptown Radiology Associates, PLLC accept Texas Workers’ Compensation reimbursement rates? ANSWER: 34. Approximately what percentage Uptown Radiology Associates, PLLC patients utilize some form of insurance, whether governmental or private, to pay for the services provided by Uptown Radiology Associates, PLLC? Are all of those services reimbursed at less than the billed amount? ANSWER: 35. Is it a common practice for Uptown Radiology Associates, PLLC to accept less than the amount Uptown Radiology Associates, PLLC bills for the services it provides? ANSWER: 36. In cases such as this where the patient is involved in litigation and Uptown Radiology Associates, PLLC was not paid until after the lawsuit is resolved, does Uptown Radiology Associates, PLLC typically accept less than the amount Uptown Radiology Associates, PLLC billed for the services it provided? ANSWER: Page 8 of 13 Medical Factoring 37. Does Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present? ANSWER: 38. Has Uptown Radiology Associates, PLLC received any payments from any third-party financing, medical factoring, or medical funding company relating to the medical treatment and services provided to Barbara Agbanyim from 12/16/2021 to the present? ANSWER: 39. Has Barbara Agbanyim or provided documentation or correspondence to Uptown Radiology Associates, PLLC from a medical funding company, medical factoring company, or related to third-party financing for the medical treatment and services provided to Barbara Agbanyim 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 Uptown Radiology Associates, PLLC to the questions identified. ANSWER: WITNESS(ES) Page 9 of 13 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 10 of 13 EXHIBIT A The subpoenaed documents described below are related to the following described patient: Patient Name: Barbara Agbanyim Date of Birth: 3/8/1956 Address: 2811 Rowland Drive, Seagoville, TX 75159 Social Security No: XXX-XX-1280 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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 Uptown Radiology Associates, PLLC’s cash rates applicable to the medical services provided to Barbara Agbanyim by Uptown Radiology Associates, PLLC from 12/16/2021 to the present, including but not limited to any rate Uptown Radiology Associates, PLLC 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 Barbara Agbanyim to Uptown Radiology Associates, PLLC in connection with medical services provided to Barbara Agbanyim 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 Barbara Agbanyim identifying, denying or accepting coverage for said medical expenses. All contracts and agreements between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim by Uptown Radiology Associates, PLLC 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. Page 11 of 13 This request specifically seeks any contracts, agreements or rates that would have been applicable to any medical services provided to Barbara Agbanyim the time period requested, regardless of whether any applicable contractual rates were actually applied and regardless of whether any bills or charges for medical services provided to Barbara Agbanyim were actually submitted to any insurance carrier for payment. All written correspondence to or from Barbara Agbanyim or their attorney relating to charges and bills for medical services provided to Barbara Agbanyim 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 Barbara Agbanyim 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 Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. All documents describing, referring to, or governing the terms of any financial, contractual, or business relationship between Uptown Radiology Associates, PLLC any third-party financing, medical factoring, or medical funding company relating to any diagnosis or treatment given in connection to Barbara Agbanyim 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 Barbara Agbanyim from 12/16/2021 to the present. 11 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 12 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 13 All correspondence between Uptown Radiology Associates, PLLC 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 Page 12 of 13 in connection with the medical treatment provided to Barbara Agbanyim from 12/16/2021 to the present. 14 All correspondence between Uptown Radiology Associates, PLLC 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 Barbara Agbanyim from 12/16/2021 to the present. 15. All communications between Barbara Agbanyim and Uptown Radiology Associates, PLLC 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 Barbara Agbanyim. 17 All documents related to how Barbara Agbanyim was referred to Uptown Radiology Associates, PLLC, 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 Uptown Radiology Associates, PLLC a financial interest in the outcome of this litigation. 19 The complete contents of Uptown Radiology Associates, PLLC’s Electronic Health Records (EHR) or Electronic Medical Records (EMR), or any other such software relating to Barbara Agbanyim, 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