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067-315266-20 FILED
TARRANT COUNTY
5/18/2020 4:34 PM
THOMAS A. WILDER
DISTRICT CLERK
NO. 067-315266-20
REBECCA CASTRO § IN THE DISTRICT COURT
PLAINTIFF, §
§
§
VS. § TARRANT COUNTY, TEXAS
§
BRETT POTTER AND ASHELY TATUM §
DEFENDANTS. § 67TH JUDICIAL DISTRICT
DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO PLAINTIFF’S
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS
Pursuant to Tex R. Civ. P. 194, Defendants serve the following First Supplemental
Response to Plaintiff’s Request for Disclosure and Designation of Experts.
f. For any testifying expert:
1. The expert’s name, address, and telephone number;
2. The subject matter on which the expert will testify;
3. The general substance of the expert’s mental impressions and opinions and
a brief summary of the basis for them, or if the expert is not retained by, employed by, or
otherwise subject to the control of the responding party, documents reflecting such
information;
4. If the expert is retained by, employed by, or otherwise subject to the control
of the responding party:
A. All documents, tangible things, reports, models, or data
compilations that have been provided to, reviewed by, or prepared by or for the
expert in anticipation of the expert’s testimony; and
B. The expert’s current resume or bibliography.
Response: Defendants hereby designate and reserve the right to call any expert witness(es)
designated by any other party to this case, as well as any experts later designated
by any party to this case on any subject relevant to this litigation on which the
witness is qualified to testify. In the event that any party to this cause has
designated any experts but has been or is subsequently dismissed for any reason or
fails to call any designated expert at the time of trial, Defendants specifically
reserve the right to call any such expert previously designated by that party.
Defendants further reserve the right to withdraw or de-designate any expert prior
DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1-
to testimony and to positively aver that such previously designated expert will not
be called as a witness at trial and to redesignate same as a consulting expert who
will not be called by any party in this cause. Finally, Defendants reserve the right
to supplement this response as additional information concerning experts becomes
available.
Defendants further hereby designate as adverse expert witnesses all expert
witnesses designated by Plaintiff. Defendants reserve the right to rely upon or to
offer, by direct examination or cross-examination, testimony obtained from those
experts and rebuttal experts, if any, designated by Plaintiff. By this designation,
Defendants do not necessarily agree with, nor vouch for, the credibility of any such
witnesses or their opinions, or the reliability, materiality, or admissibility of
information and/or tangible things produced by these individuals in general; by this
designation Defendants are simply reserving the opportunity to rely upon or elicit
certain opinions and/or evidence from these witnesses to the extent that it deems it
in its interest to do so.
Such persons are expected to testify concerning Plaintiff’s care and treatment. See
Plaintiff’s Responses to Defendants’ Request for Disclosure for additional
information concerning such health-care providers including medical bills and
records relating to Plaintiff.
First Supplemental Response:
Defendants hereby designate as an expert witness the following individual:
Christopher Happ, D.O
6900 Harris Parkway
Fort Worth, Texas 76132
817.707.0200
Dr. Happ is a Texas physician and board certified orthopedic surgeon who has reviewed
Rebecca Castro’s medical records and other case materials provided to him and is
expected to testify regarding the extent of the injuries sustained by the Plaintiff in the
subject motor vehicle accident, the appropriate care and treatment for those injuries, and
the fair and reasonable cost of that treatment, both in the past and in the future, if applicable,
as set out in the attached report.
DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2-
Respectfully submitted,
___________________________________
Chad Kimble, State Bar No. 24007483
Kyle Smith, State Bar No. 24102512
D. Brent Beasley, State Bar No. 24082669
LAW OFFICE OF CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANTS
CERTIFICATE OF SERVICE
The undersigned certifies that on the 18th day of May, 2020, a true copy of the foregoing
has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure.
____________________________________
Brent Beasley
DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO
REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3-
CHRISTOPHER HAPP, D.O. 12001 N. CENTRAL EXPRESSWAY
AMERICAN ACADEMY OF ORTHOPEDIC SURGEONS SUITE 800
AMERICAN OSTEOPATHIC ACADEMY OF ORTHOPEDICS DALLAS, TX 75243
(214) 750-6110
FAX - (214) 750-5825
May 8, 2020
Mr. Chad Kimble
Law Office of Chad Kimble
1204 South White Chapel Blvd.
Southlake, TX 76092
RE: Rebecca Castro
CLAIM #: 0547790303
DATE OF INJURY: 05/31/19
CASE#: 21116478
Dear Mr. Kimble:
I have had the opportunity to review medical records on Ms. Rebecca Castro.
My name is Christopher M. Happ, D.O. I am a aboard-certified, fellowship trained practicing orthopedic spine
surgeon in the Dallas-Fort Worth area since 2014. I was asked to review records on Ms. Rebecca Castro. As a
practicing orthopedic spine surgeon, I am tasked daily with differentiating and diagnosing orthopedic and
spine pathology and determining treatment including conservative management, injections and surgical
intervention. I also own a private practice and I am very familiar with billing, coding, reimbursements, and cost
of implants. In addition, I siton a local committee at a major healthcare system hospital tasked with
decreasing orthopedic and spine surgery costs and implants associated with them.
REVIEW OF MEDICAL RECORDS:
Review of records for the patient starts with police report on May 31, 2019. The police report states she was
struck from behind and pushed into the car in front of her, she was stopped. The car experienced heavy and
severe damage. The patient was taken to Harris Hospital via MedStar.
Next is a report from MedStar record on May 31, 2019. The patient reports being a restrained driver. Pain down
the left side of her body from the neck to the torso. No loss of consciousness. The patient was able to stand up
to be moved to the stretcher, but was not ambulatory from the car to the stretcher at scene. The patient was
then taken to Texas Health Resources Hospital at Fort Worth. The patient arrived at 16:50 hours, reporting
cervical strain, left shoulder sprain, shoulder blade pain, collar bone pain and hand pain. There were no acute
neurologic deficits noted. On physical exam, x-rays of the left shoulder, lumbar spine, thoracic spine, and chest
were performed. CT of the cervical spine and CT of the head were performed, none of which revealed any
acute injuries, fluid collections, edema, fractures or dislocations. The patient was started the discharge process
at 18:46 hrs. The patient was given Tramadol and Robaxin.
The patient followed up on June 12, 2019 at 360 Back and Spine Center and saw Melanie B. Kinchen, M.D. The
patient reported having cervical and lumbar spine pain and left shoulder pain. Pain worse with sneezing. Left
shoulder pain worse with use and diminished range of motion of the left shoulder. Of note, in Dr. Kinchen’s
narrative, there is mention that during the visit,the patient reported pain; however, when the patient was
leaving, she was able to lift
her arm above her head without any pain, which is concerning for malingering.
The patient reports physical therapy as ineffective, last physical therapy being on June 12, 2015. This suggests
that the patient has had previous therapy for neck and/or low back and/or left shoulder pain. The patient also
reports seeing chiropractor and getting trigger point injections on June 12, 2015. On physical exam, the patient
Rebecca Castro
May 8, 2020
CASE #: 21116478
Page 2 of 4
is 5 feet 5 inches and 390 pounds. The patient has left upper extremity numbness and axial neck and low back
pain without deficit. The patient was diagnosed with cervical disc disorder with radiculopathy and left shoulder
pain. There is a prior history of neck and back pain from a motor vehicle collision four years ago noted in the
history. Dr. Kinchen ordered an MRI of the cervical and lumbar spine, gave the patient Medrol Dosepak,
Robaxin, and Tramadol.
On June 27, 2019, the patient was seen at Envision with an MRI of the cervical and lumbar spine that revealed
disc osteophyte complex at C5-6 and C6-7 with no significant stenosis. These are degenerative changes either
due to genetics, lifestyle or weight. On the lumbar spine, there are no acute changes. There is no recent
inflammation of facets at L3-4, L4-5, and L5-S1, but no fractures, muscular edema, ligamentous edema,
dislocations, disc herniations or stenosis.
The patient was followed by Dr. Kinchen on July 8, 2019. The patient reports being well-enough to go to
SeaWorld and push her mother around the park in a wheelchair. Dr. Kinchen recommended no further
treatment for cervical or lumbar spine. Continue the home exercise program.
SUMMARY OF MEDICAL RECORDS:
The patient did undergo motor vehicle collision and had cervical and lumbar sprain and left shoulder sprain.
However, there is no neurologic deficit noted, no significant compressive pathology or acute changes on MRI
of the cervical or lumbar spine. Also, there is question of malingering as the patient on exam reported having
pain. However, when leaving the office had no pain with motion of the left shoulder. The patient has a
previous history of cervical and low back pain with physical therapy, chiropractic care and trigger point
injections in the past and the patient is morbidly obese. The patient’s treatment was necessary as far as visit.
However, the patient did not undergo any recent physical therapy due to previous pain in the past. However,
this should have been attempted. Also, the MRIs were unindicated as the patient had numbness in the hand,
but no neurologic deficits, and had not been unsuccessful with physical therapy.
As far as billing, billingfor the two office visitsat 360 Back and Spine, the initial visitwas charged $3300 and
follow-up visit was $2163. Normal initial consultation reimbursement is between $200 and $350 depending on
the extent of the visit and the level of coding. This was not visible on the billing sheet. Follow-up visits normally
range between $120 and $210 depending on the level of coding and therefore both of these are significantly
multiple above where they should be. Also, there was a urine drug screen performed, which cost $5998. These
represent a significant inflation as the urine drug screen can regularly be performed for around $500 even with
extensive panels. Also, the patient’s cervical and lumbar spine MRIs were significantly inflated in cost. The
patient was charged $4018 for cervical spine and $3951 for lumbar spine. Normally, these can be performed
for $500 to $700 cash.
All in all, charges were significantly inflated. Treatment was reasonable as far as seeing Dr. Kinchen. However,
MRIs were unnecessary. The patient should have undergone physical therapy in the absence of a neurologic
deficit.
Thank you for the opportunity to review the medical records on Ms. Rebecca Castro.
Rebecca Castro
May 8, 2020
CASE #: 21116478
Page 3 of 4
Dictated, reviewed, opinion verified, and attested to by my original signature.
Sincerely,
Christopher Happ, D.O.
American Academy of Orthopedic Surgeons
American Osteopathic Academy of Orthopedics
P5186
CH/sm:ANS/sam
The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the
basis of the medical records provided, with the assumption that the material is true and correct. If more
information becomes available at a later date, an additional service/report/reconsideration may be
requested.
Rebecca Castro
May 8, 2020
CASE #: 21116478
Page 4 of 4
SUMMARY OF RECORDS
• Texas Peace Officer’s Crash Report, 05/31/19
• MedStar Mobile Healthcare Patient Care Report, 05/31/19
• Texas Health Fort Worth Emergency Department, Jason Scott Biggers, M.D./James Kogan, M.D./William
Reese, M.D./Stephan Geppert, M.D., 05/31/19
• 360 Back and Spine Center, Melanie B. Kinchen, M.D., 06/12/19, 07/08/19
• Envision Imaging, Ravi Bodiwala, M.D., 06/27/19
• Plaintiff’s Responses to Defendant’s First Request for Disclosure, 04/23/20
• Affidavit of Records Custodian of MedStar Mobile Healthcare, 06/21/19
• Affidavit of Billing Records Custodian of Texas Health Resources, 03/16/20
• Affidavit of Billing Records Custodian of Texas Medicine Resources, LLP, 07/17/19
• Affidavit of Records Custodian of Radiology Associates of North Texas, 07/10/19
• Affidavit of Records Custodian of 360 Back & Spine Center, 09/23/19
• Medical Records Affidavit, 09/23/19
• Affidavit of Records Custodian of Elite Medical Laboratory, 10/09/19
• Affidavit of Records Custodian of Envision Imaging at Pennsylvania, 09/26/19
• Medical Records Affidavit, 09/26/19
• Vehicle Color Photos, 10 pages
• Itemized Statement, Metropolitan Area EMS Auth dba MedStar Mobile Health, Statement Date:
03/10/20; Date of Service: 05/31/19
• Patient Account Summary, Texas Health Resources, undated
• Itemized Statement, Texas Health Resources, Statement Date: 03/12/20; Date of Service: 05/31/19
• UB-04 Claim Image, Texas Health Fort Worth, Date of Service: 05/31/19
• Itemized Statement, Texas Medicine Resources, Statement Date: 07/16/19; Date of Service: 05/31/19
• Itemized Statement, Radiology Associates of North Texas, Statement Date: 07/10/19; Date of Service:
05/31/19
• Itemized Statement, 360 Back and Spine Center, Melanie B. Kinchen, M.D., Statement Date: 09/23/19;
Dates of Service: 06/12/19 – 07/08/19
• Health Insurance Claim Form, Elite Medical Laboratory, Statement Date: 08/07/19; Date of Service:
06/12/19
• Itemized Statement, Health Imaging Partners LLC DBA, Statement Date: 09/25/19; Date of Service:
06/27/19
• Health Insurance Claim Form, Envision Imaging of Pennsylvania, Ravi Kishor Bodiwala, M.D., Statement
Date: 07/03/19; Date of Service: 06/27/19
CHRISTOPHER HAPP, D.O.
Orthopedic Spine Surgeon
EDUCATION
Texas Back Institute
July 2013 – June 2014
Orthopedic Spine Surgery Fellow
Midwestern University- Chicago College of Osteopathic Medicine
August 2008 – June 2013
Medical student at Downers Grove campus followed by internship and
residency in orthopedic surgery.
Loyola University Chicago
August 2004 – May 2008
Bachelors of Science in Chemistry, Minor in Biology and Philosophy, Lab
Assistant for 3 years in microbiology lab.
WORK EXPERIENCE
DFW Center for Spinal Disorders Orthopedic Spine Surgeon
August 2014–Present
Member of multi provider spine surgeon group based out of Fort Worth
Texas.
Board Certified by the AOBOS in 2017
PROFESSIONAL AFFILIATIONS
North American Spine Society
American Academy of Orthopedic Surgeons
American Osteopathic Academy of Orthopedics
HOSPITAL AFFILIATIONS
Texas Health Harris Methodist Hospital Fort Worth
Texas Health Harris Methodist Hospital Southwest
Baylor Surgical Hospital at Fort Worth
SKILLS
General practice spine surgeon specializing in degenerative spine
surgery with emphasis on patient centered care and minimally invasive
surgical techniques. Familiar with MIS, robotic, navigation guided
surgeries.
Preview
067-315266-20 FILED TARRANT COUNTY 5/18/2020 4:34 PM THOMAS A. WILDER DISTRICT CLERK NO. 067-315266-20 REBECCA CASTRO § IN THE DISTRICT COURT PLAINTIFF, § § § VS. § TARRANT COUNTY, TEXAS § BRETT POTTER AND ASHELY TATUM § DEFENDANTS. § 67TH JUDICIAL DISTRICT DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO PLAINTIFF’S REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS Pursuant to Tex R. Civ. P. 194, Defendants serve the following First Supplemental Response to Plaintiff’s Request for Disclosure and Designation of Experts. f. For any testifying expert: 1. The expert’s name, address, and telephone number; 2. The subject matter on which the expert will testify; 3. The general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; 4. If the expert is retained by, employed by, or otherwise subject to the control of the responding party: A. All documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and B. The expert’s current resume or bibliography. Response: Defendants hereby designate and reserve the right to call any expert witness(es) designated by any other party to this case, as well as any experts later designated by any party to this case on any subject relevant to this litigation on which the witness is qualified to testify. In the event that any party to this cause has designated any experts but has been or is subsequently dismissed for any reason or fails to call any designated expert at the time of trial, Defendants specifically reserve the right to call any such expert previously designated by that party. Defendants further reserve the right to withdraw or de-designate any expert prior DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -1- to testimony and to positively aver that such previously designated expert will not be called as a witness at trial and to redesignate same as a consulting expert who will not be called by any party in this cause. Finally, Defendants reserve the right to supplement this response as additional information concerning experts becomes available. Defendants further hereby designate as adverse expert witnesses all expert witnesses designated by Plaintiff. Defendants reserve the right to rely upon or to offer, by direct examination or cross-examination, testimony obtained from those experts and rebuttal experts, if any, designated by Plaintiff. By this designation, Defendants do not necessarily agree with, nor vouch for, the credibility of any such witnesses or their opinions, or the reliability, materiality, or admissibility of information and/or tangible things produced by these individuals in general; by this designation Defendants are simply reserving the opportunity to rely upon or elicit certain opinions and/or evidence from these witnesses to the extent that it deems it in its interest to do so. Such persons are expected to testify concerning Plaintiff’s care and treatment. See Plaintiff’s Responses to Defendants’ Request for Disclosure for additional information concerning such health-care providers including medical bills and records relating to Plaintiff. First Supplemental Response: Defendants hereby designate as an expert witness the following individual: Christopher Happ, D.O 6900 Harris Parkway Fort Worth, Texas 76132 817.707.0200 Dr. Happ is a Texas physician and board certified orthopedic surgeon who has reviewed Rebecca Castro’s medical records and other case materials provided to him and is expected to testify regarding the extent of the injuries sustained by the Plaintiff in the subject motor vehicle accident, the appropriate care and treatment for those injuries, and the fair and reasonable cost of that treatment, both in the past and in the future, if applicable, as set out in the attached report. DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -2- Respectfully submitted, ___________________________________ Chad Kimble, State Bar No. 24007483 Kyle Smith, State Bar No. 24102512 D. Brent Beasley, State Bar No. 24082669 LAW OFFICE OF CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANTS CERTIFICATE OF SERVICE The undersigned certifies that on the 18th day of May, 2020, a true copy of the foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. ____________________________________ Brent Beasley DEFENDANTS’ FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR DISCLOSURE AND DESIGNATION OF EXPERTS -3- CHRISTOPHER HAPP, D.O. 12001 N. CENTRAL EXPRESSWAY AMERICAN ACADEMY OF ORTHOPEDIC SURGEONS SUITE 800 AMERICAN OSTEOPATHIC ACADEMY OF ORTHOPEDICS DALLAS, TX 75243 (214) 750-6110 FAX - (214) 750-5825 May 8, 2020 Mr. Chad Kimble Law Office of Chad Kimble 1204 South White Chapel Blvd. Southlake, TX 76092 RE: Rebecca Castro CLAIM #: 0547790303 DATE OF INJURY: 05/31/19 CASE#: 21116478 Dear Mr. Kimble: I have had the opportunity to review medical records on Ms. Rebecca Castro. My name is Christopher M. Happ, D.O. I am a aboard-certified, fellowship trained practicing orthopedic spine surgeon in the Dallas-Fort Worth area since 2014. I was asked to review records on Ms. Rebecca Castro. As a practicing orthopedic spine surgeon, I am tasked daily with differentiating and diagnosing orthopedic and spine pathology and determining treatment including conservative management, injections and surgical intervention. I also own a private practice and I am very familiar with billing, coding, reimbursements, and cost of implants. In addition, I siton a local committee at a major healthcare system hospital tasked with decreasing orthopedic and spine surgery costs and implants associated with them. REVIEW OF MEDICAL RECORDS: Review of records for the patient starts with police report on May 31, 2019. The police report states she was struck from behind and pushed into the car in front of her, she was stopped. The car experienced heavy and severe damage. The patient was taken to Harris Hospital via MedStar. Next is a report from MedStar record on May 31, 2019. The patient reports being a restrained driver. Pain down the left side of her body from the neck to the torso. No loss of consciousness. The patient was able to stand up to be moved to the stretcher, but was not ambulatory from the car to the stretcher at scene. The patient was then taken to Texas Health Resources Hospital at Fort Worth. The patient arrived at 16:50 hours, reporting cervical strain, left shoulder sprain, shoulder blade pain, collar bone pain and hand pain. There were no acute neurologic deficits noted. On physical exam, x-rays of the left shoulder, lumbar spine, thoracic spine, and chest were performed. CT of the cervical spine and CT of the head were performed, none of which revealed any acute injuries, fluid collections, edema, fractures or dislocations. The patient was started the discharge process at 18:46 hrs. The patient was given Tramadol and Robaxin. The patient followed up on June 12, 2019 at 360 Back and Spine Center and saw Melanie B. Kinchen, M.D. The patient reported having cervical and lumbar spine pain and left shoulder pain. Pain worse with sneezing. Left shoulder pain worse with use and diminished range of motion of the left shoulder. Of note, in Dr. Kinchen’s narrative, there is mention that during the visit,the patient reported pain; however, when the patient was leaving, she was able to lift her arm above her head without any pain, which is concerning for malingering. The patient reports physical therapy as ineffective, last physical therapy being on June 12, 2015. This suggests that the patient has had previous therapy for neck and/or low back and/or left shoulder pain. The patient also reports seeing chiropractor and getting trigger point injections on June 12, 2015. On physical exam, the patient Rebecca Castro May 8, 2020 CASE #: 21116478 Page 2 of 4 is 5 feet 5 inches and 390 pounds. The patient has left upper extremity numbness and axial neck and low back pain without deficit. The patient was diagnosed with cervical disc disorder with radiculopathy and left shoulder pain. There is a prior history of neck and back pain from a motor vehicle collision four years ago noted in the history. Dr. Kinchen ordered an MRI of the cervical and lumbar spine, gave the patient Medrol Dosepak, Robaxin, and Tramadol. On June 27, 2019, the patient was seen at Envision with an MRI of the cervical and lumbar spine that revealed disc osteophyte complex at C5-6 and C6-7 with no significant stenosis. These are degenerative changes either due to genetics, lifestyle or weight. On the lumbar spine, there are no acute changes. There is no recent inflammation of facets at L3-4, L4-5, and L5-S1, but no fractures, muscular edema, ligamentous edema, dislocations, disc herniations or stenosis. The patient was followed by Dr. Kinchen on July 8, 2019. The patient reports being well-enough to go to SeaWorld and push her mother around the park in a wheelchair. Dr. Kinchen recommended no further treatment for cervical or lumbar spine. Continue the home exercise program. SUMMARY OF MEDICAL RECORDS: The patient did undergo motor vehicle collision and had cervical and lumbar sprain and left shoulder sprain. However, there is no neurologic deficit noted, no significant compressive pathology or acute changes on MRI of the cervical or lumbar spine. Also, there is question of malingering as the patient on exam reported having pain. However, when leaving the office had no pain with motion of the left shoulder. The patient has a previous history of cervical and low back pain with physical therapy, chiropractic care and trigger point injections in the past and the patient is morbidly obese. The patient’s treatment was necessary as far as visit. However, the patient did not undergo any recent physical therapy due to previous pain in the past. However, this should have been attempted. Also, the MRIs were unindicated as the patient had numbness in the hand, but no neurologic deficits, and had not been unsuccessful with physical therapy. As far as billing, billingfor the two office visitsat 360 Back and Spine, the initial visitwas charged $3300 and follow-up visit was $2163. Normal initial consultation reimbursement is between $200 and $350 depending on the extent of the visit and the level of coding. This was not visible on the billing sheet. Follow-up visits normally range between $120 and $210 depending on the level of coding and therefore both of these are significantly multiple above where they should be. Also, there was a urine drug screen performed, which cost $5998. These represent a significant inflation as the urine drug screen can regularly be performed for around $500 even with extensive panels. Also, the patient’s cervical and lumbar spine MRIs were significantly inflated in cost. The patient was charged $4018 for cervical spine and $3951 for lumbar spine. Normally, these can be performed for $500 to $700 cash. All in all, charges were significantly inflated. Treatment was reasonable as far as seeing Dr. Kinchen. However, MRIs were unnecessary. The patient should have undergone physical therapy in the absence of a neurologic deficit. Thank you for the opportunity to review the medical records on Ms. Rebecca Castro. Rebecca Castro May 8, 2020 CASE #: 21116478 Page 3 of 4 Dictated, reviewed, opinion verified, and attested to by my original signature. Sincerely, Christopher Happ, D.O. American Academy of Orthopedic Surgeons American Osteopathic Academy of Orthopedics P5186 CH/sm:ANS/sam The opinions rendered in this case are the opinions of the evaluator. This review has been conducted on the basis of the medical records provided, with the assumption that the material is true and correct. If more information becomes available at a later date, an additional service/report/reconsideration may be requested. Rebecca Castro May 8, 2020 CASE #: 21116478 Page 4 of 4 SUMMARY OF RECORDS • Texas Peace Officer’s Crash Report, 05/31/19 • MedStar Mobile Healthcare Patient Care Report, 05/31/19 • Texas Health Fort Worth Emergency Department, Jason Scott Biggers, M.D./James Kogan, M.D./William Reese, M.D./Stephan Geppert, M.D., 05/31/19 • 360 Back and Spine Center, Melanie B. Kinchen, M.D., 06/12/19, 07/08/19 • Envision Imaging, Ravi Bodiwala, M.D., 06/27/19 • Plaintiff’s Responses to Defendant’s First Request for Disclosure, 04/23/20 • Affidavit of Records Custodian of MedStar Mobile Healthcare, 06/21/19 • Affidavit of Billing Records Custodian of Texas Health Resources, 03/16/20 • Affidavit of Billing Records Custodian of Texas Medicine Resources, LLP, 07/17/19 • Affidavit of Records Custodian of Radiology Associates of North Texas, 07/10/19 • Affidavit of Records Custodian of 360 Back & Spine Center, 09/23/19 • Medical Records Affidavit, 09/23/19 • Affidavit of Records Custodian of Elite Medical Laboratory, 10/09/19 • Affidavit of Records Custodian of Envision Imaging at Pennsylvania, 09/26/19 • Medical Records Affidavit, 09/26/19 • Vehicle Color Photos, 10 pages • Itemized Statement, Metropolitan Area EMS Auth dba MedStar Mobile Health, Statement Date: 03/10/20; Date of Service: 05/31/19 • Patient Account Summary, Texas Health Resources, undated • Itemized Statement, Texas Health Resources, Statement Date: 03/12/20; Date of Service: 05/31/19 • UB-04 Claim Image, Texas Health Fort Worth, Date of Service: 05/31/19 • Itemized Statement, Texas Medicine Resources, Statement Date: 07/16/19; Date of Service: 05/31/19 • Itemized Statement, Radiology Associates of North Texas, Statement Date: 07/10/19; Date of Service: 05/31/19 • Itemized Statement, 360 Back and Spine Center, Melanie B. Kinchen, M.D., Statement Date: 09/23/19; Dates of Service: 06/12/19 – 07/08/19 • Health Insurance Claim Form, Elite Medical Laboratory, Statement Date: 08/07/19; Date of Service: 06/12/19 • Itemized Statement, Health Imaging Partners LLC DBA, Statement Date: 09/25/19; Date of Service: 06/27/19 • Health Insurance Claim Form, Envision Imaging of Pennsylvania, Ravi Kishor Bodiwala, M.D., Statement Date: 07/03/19; Date of Service: 06/27/19 CHRISTOPHER HAPP, D.O. Orthopedic Spine Surgeon EDUCATION Texas Back Institute July 2013 – June 2014 Orthopedic Spine Surgery Fellow Midwestern University- Chicago College of Osteopathic Medicine August 2008 – June 2013 Medical student at Downers Grove campus followed by internship and residency in orthopedic surgery. Loyola University Chicago August 2004 – May 2008 Bachelors of Science in Chemistry, Minor in Biology and Philosophy, Lab Assistant for 3 years in microbiology lab. WORK EXPERIENCE DFW Center for Spinal Disorders Orthopedic Spine Surgeon August 2014–Present Member of multi provider spine surgeon group based out of Fort Worth Texas. Board Certified by the AOBOS in 2017 PROFESSIONAL AFFILIATIONS North American Spine Society American Academy of Orthopedic Surgeons American Osteopathic Academy of Orthopedics HOSPITAL AFFILIATIONS Texas Health Harris Methodist Hospital Fort Worth Texas Health Harris Methodist Hospital Southwest Baylor Surgical Hospital at Fort Worth SKILLS General practice spine surgeon specializing in degenerative spine surgery with emphasis on patient centered care and minimally invasive surgical techniques. Familiar with MIS, robotic, navigation guided surgeries.