Preview
FILED
5/12/2021 3:15 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
CAUSE NO. DC-21-03224
SHANTE WATSON; IN THE DISTRICT COURT OF
Plaintiff,
vs. DALLAS COUNTY, TEXAS
JOSHUA BROWN; AND TOWN
EAST HEATING & AIR
CONDITIONING CO., LLC;
Defendants. 134TH JUDICIAL DISTRICT
PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND
CERTIFIED COPIES
Plaintiff Snante Watson files with the Court the attached record affidavits
and certified copies:
STATE RECORDS:
1. Certified Copy of the Police Report
2. Certified Copy of Defendant Joshua Brown’s Driving Record
MEDICAL RECORDS:
A-Medical Advantage Healthcare Systems affidavit dated 4/13/2021
Christus EMS affidavit dated 10/28/2020
Christus Mother Frances affidavit dated 10/28/2020
Elevate Health Clinics, LLC affidavit dated 3/18/2021
MRI Centers of Texas affidavit dated 10/21/2020
PHI Air Medical affidavit dated 12/21/2020
Smith County Healthcare Systems affidavit dated 4/13/2021
The Spine & Orthopedic Academic Research Institute affidavit dated
4/1/2021
Tyler Open MRI and Diagnostic Center affidavit dated 4/16/2021
BILLING RECORDS:
4
. A-Medical Advantage Healthcare Systems affidavit dated 4/13/2021
2 . Christus Mother Frances affidavit dated 9/2/2020
3 Elevate Health Clinics, LLC affidavit dated 3/15/2021
4 MRI Centers of Texas affidavit dated 10/21/2020
PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED
COPIES— Page 1
PHI Air Medical affidavit dated 12/21/2020
Smith County Healthcare Systems affidavit dated 4/13/2021
The Spine & Orthopedic Academic Research Institute affidavit dated
4/1/2021
8 Trinity Clinic affidavit dated 3/15/2021
9. Tyler Open MRI and Diagnostic Center affidavit dated 4/16/2021
10.Uptown Radiology Associates affidavit dated 3/15/2021
RADIOLOGY IMAGING
1. Christus Mother Frances affidavit dated 4/6/2021
2. MRI Centers of Texas affidavit dated 3/21/2021
By copy of this notice, opposing counsel are notified that these affidavits and
certified copies are being filed with the Court pursuant to TRE 902. The certified
copies, records, and radiology corresponding to the enclosed affidavits will be kept
in Plaintiffs counsel's office for use at trial. Opposing counsel have been
previously provided with a copy of the affidavits and corresponding
records/radiology and the certified copies listed above.
PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED
COPIES — Page 2
Respectfully submitted,
WITHERITE LAW GROUP, PLLC
By: /s/ Adewale Odetunde
ADEWALE ODETUNDE
State Bar No. 24088146
adewale.odetunde@witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shelly.greco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
| hereby certify that a true and correct copy of the foregoing has been
forwarded to all counsel of record on this 12' day of May, 2021, pursuant to the
Texas Rules of Civil Procedure.
/s/ Adewale Odetunde
Adewale Odetunde
Sandra Liser
Naman Howell Smith & Lee, PLLC
306 West 7th Street, Suite 405
Fort Worth Club Building
Fort Worth, TX 76102-4911
J. Brantley Saunders
Saunders, Walsh & Beard
6850 TPC Drive
Suite 210
McKinney, TX 75070
PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED
COPIES— Page 3
or Pe TEXAS DEPARTMENT OF PUBLIC SAFETY
hr
&
“i §805 N LAMAR BLVD + BOX 4087 « AUSTIN, TEXAS 78773-0001
www.
te
xa.
DRIVER | INSE DIVISION toe
512-424-2¢
51
STEVEN C. McCRAW EN RSPANOL 512-424-7181 COMMISSION
DIRECTOR STEVENP. MACH, CHAIRMAN
FREEMAN F. MARTIN NELDA L. BLAIR
RANDALL B. PRINCE STEVE H. STODGHILL
JEOFF WILLIAMS DALE WAINWRIGHT
OEPUTY DIRECTORS
CERTIFIED ABSTRACT RECORD: 09/25/2020
. THIS TYPE OF RECORD WILL. REFLECT COMPLETION OF A DRIVING SAFETY COURSE.
= THIS RECORD REFLECTS ENFORCEMENT ACTIONS, CONVICTIONS, AND CRASH INVOLVEMENTS THAT ARE ALLOWED
TO BE DISPLAYED BY LAW.
BROWN, JOSHUA NEIL
207 SOUTHRIDGE ST i Date of Birth: 11/07/1988
EDGEWOOD, TX 75117 Sex: MALE
REPORT OF APPROVED DRIVER EDUCATION COURSE. Eye Color: GREEN
DRIVER LICENSE AND COMMERCIAL LEARNERS PERMIT INFORMATION
Driver License Number: License Type: DL License Class: Cc
Date Originally Issued: 10/04/2005 Date Last Issued: 08/07/2020 Date of Expiration: 11/07/2025
Restrictions: NONE
Endorsements: NONE
STATUS INFORMATION Driver eligibility reflects @ person's oligibility to dive at the time this document was requested.
Administrative Status details additional notes related to the person's record that do.not affect driving eligibility.
Driver Eligibility: ELIGIBLE
Administrative Status: NONE
ENFORCEMENT ACTION HISTORY This section displays enforcement actions that may affect a person's eligibility
rive. Additional information pertaining to any event related to the enforcement
action can be found in the Event Section of this record.
ACTION 1 PENDING ALR SUSPENSION - REFUSAL
Begin Date: 09/24/2020 End Date: 03/22/2021
Notice Date: 08/15/2020
State: TX
Hearing Request Date: 08/17/2020
Related Event(s): NONE
ACTION 2 LIFTED DENIED RENEWAL - FAILURE TO APPEAR
Begin Date: 11/08/2019 End Date: INDEFINITE
Lift Date: 11/26/2019 Order Date: 11/10/2019
State: TX
Related Event(s): NONE
Page 1
|BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020
ACTION 3 LIFTED SR SUSPENSION - LIABILITY JUDGMENT
Begin Date: 08/16/2012 End Date: INDEFINITE
Lift Date: 04/18/2013 Order Date: 08/18/2012
State: TX
Related Event(s) NONE
ACTION 4 EXPIRED DEPT SUSPENSION - DWLI
Begin Date: 08/26/2011 End Date: 02/18/2012
Notice Date: 07/14/2011
State: TX
Related Event(s). NONE
ACTION 5 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE
Begin Date: 08/10/2011 End Date: INDEFINITE
Lift Date: 08/11/2011
State: TX
Related Event(s): EVENT 8
ACTION 6 LIFTED SUSPENDED - SURCHARGE DUE NO INS
Begin Date: 08/10/2011 End Date: INDEFINITE
Lift Date: 08/41/2011
State: ™
Related Event(s) EVENT9
ACTION 7 LIFTED SUSPENDED - SURCHARGE DUE NO INS
Begin Date: 08/10/2014 End Date: INDEFINITE
Lift Date: 08/41/2011
State: TX
Related Event(s): EVENT 7.
ACTION 8 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE
Begin Date: 11/15/2010 End Date: INDEFINITE
Lift Date: 02/03/2011
State: TX
Related Event(s) EVENT 6
ACTION 9 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO DRIVER
LICENSE
Begin Date: 10/19/2010 End Date: INDEFINITE
Lift Date: 02/03/2011
State: TX
Related Event(s): EVENT 4
ACTION 10 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS
Begin Date: 08/23/2010 End Date: INDEFINITE
Lift Date: 02/03/2011
State: TX
Related Event(s) EVENT 9
ACTION 11 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO DRIVER
LICENSE
Begin Date: 08/11/2010 End Date: INDEFINITE
Lift Date: 02/03/2011
State: TX
Page 2
LEROWN, JUSKIVA NEIL - CERTIFIED ABOITRAGT RECORD - U9/20/2020
Related Events): EVENT 8
ACTION 12 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS
Begin Date: 08/14/2010 End Date: NDEFINITE
Lift Date: 02/03/2011
State: TX
Related Event(s) EVENT 7
ACTION 13 LIFTED SR SUSPENSION - NO LIABILITY INSURANCE
Begin Date: 03/01/2010 End Date: INDEFINITE
Lift Date: 01/19/2010 Order Date: 02/10/2010
State: TX
Related Event(s) EVENT 7; EVENT 9; EVENT 12
ACTION 14 LIFTED SR SUSPENSION - NO LIABILITY INSURANCE
Begin Date: 04/06/2009 End Date: INDEFINITE
Lift Date: 04/06/2009 Order Date: 03/19/2009
State: T™X
Related Event(s): EVENT 7
ACTION 15 LIFTED SUSPENDED - SURCHARGE DUE NO INS
Begin Date: 04/09/2009 End Date: INDEFINITE
Lift Date: 02/03/2009
State: T™
Related Event(s) NONE
ACTION 16 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE
Begin Date: 09/42/2008 End Date: INDEFINITE
Lift Date: 09/18/2008
State: 1™
Related Event(s) NONE
ACTION 17 LIFTED DENIED RENEWAL - FAILURE TO APPEAR
Begin Date: 07/23/2008 End Date: INDEFINITE
Lift Date: 01/30/2009
State: TX
Related Event(s) NONE
ACTION 18 LIFTED SUSPENDED ~- SURCHARGE DUE NO INS
Begin Date: 01/10/2008 End Date: INDEFINITE
Lift Date: 02/26/2008
State: ™
Related Event(s) NONE
ACTION 19 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS
Begin Date: 08/13/2007 End Date: INDEFINITE
Lift Date: 09/19/2007
State: TX
Related Event(s) NONE
ACTION 20 EXPIRED ALR SUSPENSION - UNDER 21 - FAILURE
Begin Date: 07/14/2007 End Date: 09/11/2007
Notice Date: 06/04/2007
State: TX
Related Event(s) NONE
Page 3
|BROWN, JOSHUA NEIL_- CERTIFIED ABSTRACT RECORD - 09/25/2020
ACTION 21 LIFTED SUSPENDED - SURCHARGE DUE NO INS
Begin Date: 01/10/2007 End Date: INDEFINITE
Lift Date: 03/26/2007
State: TX
Related Event(s): NONE
~
DRIVER RESPONSIBILITY PROGRAM (DRP) This section displays information relating the Driver Responsibility
Program,
tr
Any su: S| ension action resulting from a notice will be
referenced in the Enforcement Action History Section.
SURCHARGE 1 CASE 12896746657323125600 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 2: 06/29/2011
Default Date: 08/10/2011
Complied Amnesty Date 08/11/2011
SURCHARGE 2 CASE 42463368999843923680 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 3: 06/29/2011
Default Date: 08/40/2011
Complied Amnesty Date: 08/41/2014
SURCHARGE 3 CASE 12012348355054916210 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 3: 06/29/2014
Default Date: 08/10/2011
Complied Amnesty Date: 08/11/2014
SURCHARGE 4 CASE 21447463574061649250 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 3: 10/04/2010 Complied Date: 06/23/2011
Default Date: 11/15/2010
Complied Amnesty Date: 06/28/2011
SURCHARGE 5 CASE 79392132408156008060 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 3: 08/09/2010 Complied Date: 06/23/2014
Installment Agreement Date: 09/08/2010 tnstallment Agreement Default Date: 40/19/2010
Complied Amnesty Date: 06/28/2011
SURCHARGE 6 CASE 71700982818196166300 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 2: 03/31/2010 Complied Date: 06/23/2011
installment Agreement Date: 05/03/2010 Installment Agreement Default Date: 08/11/2010
Complied Amnesty Date: 06/28/2011
SURCHARGE 7 CASE 55747732239893588380 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 2: 03/31/2010 Complied Date: 06/23/2011
Installment Agreement Date: 05/03/2010 Installment Agreement Default Date: 08/11/2010
Complied Amnesty Date: 06/28/2011
SURCHARGE 8 CASE 90900175975095442330 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 1: 02/11/2010 Complied Date: 06/23/2011
Installment Agreement Date: 02/19/2010 Installment Agreement Default Date: 08/23/2010
Complied Amnesty Date: 06/28/2014
SURCHARGE 9 CASE 14569142386068949380 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 2: 09/30/2009 Complied Date: 10/26/2009
SURCHARGE 10 CASE 3969688690327 2538040 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 2: 08/05/2009 Complied Date: 40/07/2009
SURCHARGE 11 CASE 23699084A13320090765 NO INSURANCE SURCHARGE NOTICE
Page 4
| BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020
Notice Date - Year 1 03/27/2009 Complied Date: 07/21/2009
SURCHARGE 12 CASE 23699084A13420090765 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 1 03/27/2009 Complied Date: 06/15/2009
SURCHARGE 13 CASE 23699084A13320063197 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 3: 41/28/2008 Complied Date: 02/03/2009
Default Date: 01/09/2009
SURCHARGE 14 CASE 23699084A 13420082595 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 1 09/25/2008 Complied Date: 10/10/2008
SURCHARGE 15 CASE 23699084A13420082045 NO DRIVER LICENSE SURCHARGE NOTICE
Notice Date - Year 4 08/01/2008 Complied Date: 09/18/2008
Default Date: 09/12/2008
SURCHARGE 16 CASE 23699084A 13320063196 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 2: 11/29/2007 Complied Date: 02/26/2008
Default Date: 01/10/2008
SURCHARGE 17 CASE 23699084A13320063195 NO INSURANCE SURCHARGE NOTICE
Notice Date - Year 1: 11/29/2006 Complied Date: 09/19/2007
installment Agreement Date: 03/26/2007 Installment Agreement Default Date: 08/13/2007
Default Date: 01/10/2007
EVENT HISTORY This section displays information relating to convictions, crash involvement, safety courses completed,
out-of-state surrendered license history and education program certificates.
EVENT 1 CRASH NON-INJURY
Accident Date 08/02/2014 Case Number: 0013969850
State: T™ County: ECTOR
CMV: NO HAZMAT: NO
Citation: CITATION ISSUED ~ NO DISPOSITION
EVENT 2 CRASH NON-INJURY
Accident Date: 04/10/2012 Gase Number: 0012653573
City: DALLAS State: TX
CMV: NO HAZMAT: NO
Citation: NO CITATION ISSUED.
EVENT 3 CRASH NON-INJURY
Accident Date: 04/03/2012 Case Number: 0012685963
City: KAUFMAN State: TX
CMV: NO HAZMAT: NO
Citation: NO CITATION ISSUED
EVENT 4 CONVICTION EXPIRED DRIVER LICENSE
Offense Date: 05/23/2008 Conviction Date: 06/26/2008 County: DALLAS
State: TX Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No; JT0857209E
CMV: NO HAZMAT: NO CDL: NO
EVENT 5 CONVICTION SPEEDING
Offense Date: 05/23/2008 Conviction Date: 06/26/2008 County: DALLAS
Page 5
[BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020
State: ™ Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No: JT0857208E
CMV: NO HAZMAT: NO CDL: NO
EVENT 6 CONVICTION EXPIRED DRIVER LICENSE
Offense Date: 10/20/2007 Conviction Date: 11/07/2007 County: KAUFMAN
State: TX Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No: CR0728254
CMV. NO HAZMAT: NO CDL: NO
EVENT 7 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE
Offense Date: 03/06/2007 Conviction Date: 08/04/2008 County: KAUFMAN
State: TX Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No: CR071007
CMV: NO HAZMAT: NO CDL: NO
EVENT 8 CONVICTION EXPIRED DRIVER LICENSE
Offense Date: 03/06/2007 Conviction Date: 18/04/2008 County: KAUFMAN
State: TX Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No:CRO71006
CMV: NO HAZMAT: NO CDL: NO
EVENT 9 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE
Offense Date: 42/04/2006 Conviction Date: 01/29/2009 County: KAUFMAN
State: T™ Court Name Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No:CR063432
CMV. NO HAZMAT: NO CDL: NO
EVENT 10 CONVICTION SPEEDING EQUAL TO OR GREATER THAN 10% ABOVE POSTED LIMIT
Offense Date: 12/04/2006 Conviction Date: 01/29/2009 County: KAUFMAN
State: TX Court Name: Justice of the
Peace Court
(offense = Texas
Court)
Case/Cause/Docket No:CR063431
CMV: NO HAZMAT: NO CDL: NO
EVENT 14 CONVICTION SPEEDING EQUAL TO OR GREATER THAN 10% ABOVE POSTED LIMIT
Offense Date: 07/19/2006 Conviction Date: 08/25/2006
City: BALCH SPRINGS State: TX Court Name: Municipal Court
Page6
BROWN, JOSHUA NEIL_- CERTIFIED ABSTRACT RECORD - 09/25/2020
(offense = Texas
Court)
Case/Cause/Docket No: 060008926
CMV: NO HAZMAT: NO CDL: NO
EVENT 12 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE
Offense Date: 06/17/2006 Conviction Date: 07/05/2006
City: SEAGOVILLE State: TX Court Name: Municipal Court
(offense = Texas
Court)
Case/Cause/Docket No:0644135
CMV: NO HAZMAT. NO CDL: NO
Pursuant to the authority contained in the Texas Rules of Evidence 902, Section 4, and Transportation Code, Section 621, |, Mimzie L. Dennis, do
hereby certify that | am the custodian of driver records of the Driver License Division, Texas Department of Public Safety. The information contained
herein is true and correct as taken from our official records. This !s to certify that notices of convictions for the traffic taw violations and incidents of
motor vehicle accident involvement are received and recorded, along with the official action by the Department of Public Safety, in the computer records
of JOSHUA NEIL BROWN.
In Testimony Whereof, I hereunto set my hand and affix the Seal of the Department of Public Safety of the State of Texas on 09/25/2020.
oF: Dyeae.
ae
aN! hi
Ou
Mimzle L. Dennis
SHE
Texas Department of Public Safety
End of Record
Page 7
MEDICAL RECORDS AFFIDAVIT OF A-MEDICAL ADVANTAGE HEALTHCARE SYSTEMS
REGARDING PATIENT SHANTE WATSON
STATE OF TEXAS §
§
COUNTY oF __ Dulas §
BEFORE M' E, the undersigned authority, personally appeared
Kosarod
Aly , who, being by me duly sworn, deposed as follows:
My name is a . |am of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated:
| am the custodian of the records of A-Medical Advantage Healthcare Systems. Attached hereto
are records from A-Medical Advantage Healthcare Systems regarding Shante Watson. These records
are kept by A-Medical Advantage Healthcare Systems in the regular course of business, and it was in
the regular course of business for an employee or representative with knowledge of the act, event,
condition, opinion, or diagnosis recorded to make the record or to trai it information thereof to be
included in such record; and the record was made at or near the time event recorded or reasonably
soon thereafter. The records attached hereto are the original _or-e up s of the original.
— a
a RECORDS
SWORN TO AND SUBSCRIBED before me on the l 3 day of Ayal 20Ll.
bn eg?
NOTARY PUBLICAN AND FOR THE STATE OF TEXAS:
ies Carry andes
ose a NOTARY'S PRINTED NAME:
nascfet
eI aS comers
itty, LISA M. CARRIZALSS e of Texas!
ae % Notary Pub! lic, Stat
‘omm. Expires 02-18-2022
‘of ‘S Notaryeae
1D 7806
ao Sa
5 Y COMMISSION EXPIRES: 2/78 /zoze
Seam Sepa
See
RECORDS CUSTODIAN’S AFFIDAVIT AND DECLARATION
{, the undersigned, herzhy ceitify that a duly authorized ciistodian of records for Christus
EMS, and I have authority to certify said rece and copies thereof. her, I ereby certify that the
copies of records attached hereto. are tue and accurate copies of the records of Shante A, Watson, and
comprise ALL records and notes on Shaate A. Watson for ALL dates of treatient for ALE injuries,
illnesses, incidents, or azeidents which Shante A. Watson received treatment at this facility.
Thereby certify in commtiance with O.C.G A, $§ 24-8-863(6) and 24-9-902: 1) that these records:
a) Were made at or near i time of the described acts, events, conditions, opinions, or diaghdses sét
forth by or from information transmitted by a person with knowledge of such matters;
») Were kept in the course of your regularly conducted business activity;
°) Were made as the regular practice of your regularly conducted business activity; and
qd) Were made by or from information transmitted by a person with perscnal knowledge and a
business diny to report.
This 22 day of_ CNA A » 2020
ted 02
Records Custodian
-
oF Oh
. ‘ hiclr? O 7 sk oa 7
RA SF
ens)
. PRINT NAME
2 2
S Notary 3
iden
“gy sn to-and subscribed before me this
“dt. day of ©) (2020
os
\-
~
} 6 “ARY PUBLIC)
My Ci
[But 13 Expires:
a
AFFIDAVIT
Relating to the medical records of _Shante A. Watson (patient name),
for the date(s) of service __ 08/15/2020 to 10/27/2020
Before me, the undersigned authority, personally appeared Suzanne Yates
(records custodian) who, being by me duly sworn, deposed as follows:
My name is Suzanne Yates (records custodian). I am of sound mind,
capable of making this Affidavit, and personally acquainted with the facts
herein stated:
Tam the Custodian of Records for CHRISTUS Mother Frances Hospital — Tyle!
(business name).
Attached hereto are 0
273 _ page(s) and/or —_ CD(s) of medical records from CHRISTUS
Mother Frances Hospital - Tyler (business name). These records are kept by said Custodian of
Records in the regular.course of business, and it was in the regular course of business of
CHRISTUS Mother Frances Hospital - Tyler (business name) for an employee or
representative of said business with the knowledge of the act, event, condition, opinion, or
diagnosis, recorded to make the record or transmit information thereof to be included in such
record. The record was made at or near the time or reasonably soon thereafter. The records
attached hereto are the original or exact duplicates of the original(s).
Affiant
SWORN TO AND SUBSCRIBED before me on the 28 day of October 20_20_.
APRIL BOHNE
nue Behre
NOTARY PUBLIC. Notary Public, State of Texas
My Commission expires:_O. i Lf Ld vod
STATE OF TEXAS
1D #12491352-1 {
My Comm. Expires 07-18-2021
ICAL REC FIDAVIT OF ELEVATE HEALTH CLINICS, LLC
REGARDING PATIENT SHANTE WATSON
California
STATE OF HexaS §
COUNTY OF _Los Angeles §
BEFORE ME, the undersigned authority, personally appeared
Kerstin losue , who, being by me duly sworn, deposed as follows:
My name Is __ Kerstin losue . Lam of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated:
c/o Atticus Medical Billing
| am the custodian of the records of Elevate Health Clinics, LLC. Attached hereto are records
from Elevate
Clinics, LL oe shea ci
48
regarding Shante Watson. These records are kept by Elevate Health
f business, and it was in the regular course of business for an
employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded
to make the record or to transmit information thereof to be included in such record; and the record was
made at or near the time of the event recorded or reasonably soon thereafter. The records attached
hereto are the original or exact duplicates of the original. ‘
\
CUSTODIAN OF MEDICAL RECORDS
SWORN TO AND SUBSCRIBED before me onthe _15 _ day of March ,20_21
Ss ~ =
nonin mi
NOTAREPOBLIC iN FOR THE STATE OF CALIFORNIA:
5 Oe
Le #5 i f
COMM #2263804 Jennifer Nagy
Angele Gounty O
torn Notary Public ; NOTARY'S PRINTED NAME:
sure Exp. Aug. 12, 2!
Civtvetaraverat af ay
Me ssl sles ins BARR we 550
MY COMMISSION EXPIRES: __ "262+ ¢| il ULL
MEDICAL RECORDS AFFIDAVIT OF MRI CENTERS OF TEXAS
REGARDING PATIENT _ SHANTE WATSON
STATE OF TEXAS §
COUNTY OF DALLAS §
BEFORE ME, the undersigned authority, personally appeared
GALDINA SALDANA , who, being by me duly sworn, deposed as follows:
My name is GALDINA SALDANA . | am of sound mind, capable of
making this Affidavit, and personally acquainted with the facts herein stated:
| am the custodian of the records of MRI CENTERS OF TEXAS. Attached hereto are
records from MRI CENTERS OF TEXAS regarding SHANTE WATSON These records are
kept by MRI CENTERS OF TEXAS in the regular course of business, and it was in the regular
course of business for an employee or representative with knowledge of the act, event,
condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to
be included in such record; and the record was made at or near the time of the event recorded
or reasonably soon thereafter. The records attached hereto are the original or exact duplicates
of the original.
RECORDS CLERK
SWORN TO AND SUBSCRIBED before me on the 21ST day of OCTOBER
20,20
Gap? Aon
NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS:
RAQUEL ULLOA
NOTARY'S PRINTED NAME:
MY COMMISSION EXPIRES: _ 01/09/2024
p
LER RAQUEL ULLOA
é A) Notary 1D #132307314
My Commission Expires
XE January9, 2024
MEDICAL RECORDS AFFIDAVIT OF PHI AIR MEDICAL
REGARDING PATIENT SHANTE A. WATSON
STATE OF eee §
§
COUNTY OF ¥ laricopa. §
BEFORE ME. the undersigned authority, personally appeared
ROCHEL 2 BOOTHE ae who, being by me duly sworn, deposed as follows:
My name is ROCHEL BOOTHE tam of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated
| am the custodian of the records of PHI Air Medical Attached hereto are records from PHI Air
Medical regarding Shante A. Watson. These records are kept by PHI Air Medical in the regular course
of business, and it was in the regular course of business for an employee or representative with
knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit
information thereof to be included in such record; and the record was made at or near the time of the
event recorded or reasonably soon thereafter. The records attached hereto are the original or exact
duplicates of the original
CUSTODIAN OF MEDICAL RECORDS
SWORN TO AND SUBSCRIBED before me on the <2/° day ot December_ 208?
ZONA
MY COMMISSION EXPIRES 9g 30RD
CINDY ¢ GLOVE
(COPA BOUNTY
Commission # 652871
Expires September 20.
MEDICAL RECORDS AFFIDAVIT OF SMITH COUNTY HEALTHCARE SYSTEMS
REGARDING PATIENT SHANTE WATSON
STATE OF TEXAS .
§
COUNTY OF _ Dallas. §
B EFORE ME, the undersigned authority, personally appeared
Alex Kosaroud , who, being by me duly sworn, deposed as follows:
My name is oO | am of sound mind, capable of making
this Affidavit, and personally acquainted with the facts herein stated:
1 am the custodian of the records of Smith County Healthcare Systems. Attached hereto are
records from Smith County Healthcare Systems regarding Shante Watson. These records are kept by
Smith County Healthcare Systems in the regular course of business, and it was in the regular course of
business for an employee or representative with knowledge of the act, event, condition, opinion, or
diagnosis recorded to make the record or to transmit informatio fereof to be included in such record,
and the record was made at or near the time of the event rec 'd or reasonably soon thereafter. The
records attached hereto are the original or exact duplicates ie original.
_ St
-@SSTODIAN OF MEDICAL RECORDS
SWORN TO AND SUBSCRIBED! ferme on tne 13 aay ot Ayal) 20 2/
hon >
NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS
bisa tariaales
NOTARY'S PRINTED NAME:
y COMMISSION ExPIRES:_Z/ 18) 2022.
ee
mes
exes OE CRRA
iy, VE ee Te)
My syoror ws Me 9-18-2022
comm. & > 08888
Not
“nk i gue
atta
sa
MEDICAL RECORDS AFFIDAVIT OF THE SPINE & ORTHOPEDIC ACADEMIC RESEARCH
INSITUTE
REGARDING PATIENT
STATE OF TEXAS
county oF _\ Q0\\0)
ERO 2 ‘ME.
\} > _iwho,undersigned authority,
being by me duly swom,
personally
deposed as follows:
appeared
U
My name is Co (PQ | am of sound mind, capable of
making this Affidavit, and personally acquainted with the facts herein stated:
{ am the custodian of the records of The Spine & Orthopedic Academic Research Institute.
aoe eS are records from The Spine & Orthopedic Academic Research Institute regarding
ANTE We These records are kept by The Spine & Orthopedic Academic Research
In ite in the regular course of business, and it was in the regular course of business for an
employee or representative with knowledge of the act, event, condition, opinion, or diagnosis
recorded to make the record or to transmit information thereof to be included in such record; and
the record was made at or near the time of the event recorded or reasonably soon thereafter. The
records attached hereto are the original or éxa panmsie of the original.
U AIDA UW
dgeTaDt OF sca RECORDS WO)
SWORN TO AND SUBSCRIBED before me on the Ll day of ( Uy a /
20e\_
NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS:
ASHLEY EUAINE TUCKERas
c, State of Tex
Muck
tary Publi NOTARY'S PRINTED NAME.
5 10-30-2024
Comm. Expire
e a7g040s
Notary —pe12
MY COMMISSION EXPIRES: _| 0 | 90/94
>
IEDICAL RECORDS AEFFIDA' OPEN MRI AND DIAGNOSTIC SENT
| ER
REGARDING FATIENT SHANT Ee WATS ON
|‘ .
STATE OF TEXAS § i
t
COUNTY OF &A, §
ee a ME, th ie undersigned authority, personally ree
Preview
FILED 5/12/2021 3:15 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez DEPUTY CAUSE NO. DC-21-03224 SHANTE WATSON; IN THE DISTRICT COURT OF Plaintiff, vs. DALLAS COUNTY, TEXAS JOSHUA BROWN; AND TOWN EAST HEATING & AIR CONDITIONING CO., LLC; Defendants. 134TH JUDICIAL DISTRICT PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES Plaintiff Snante Watson files with the Court the attached record affidavits and certified copies: STATE RECORDS: 1. Certified Copy of the Police Report 2. Certified Copy of Defendant Joshua Brown’s Driving Record MEDICAL RECORDS: A-Medical Advantage Healthcare Systems affidavit dated 4/13/2021 Christus EMS affidavit dated 10/28/2020 Christus Mother Frances affidavit dated 10/28/2020 Elevate Health Clinics, LLC affidavit dated 3/18/2021 MRI Centers of Texas affidavit dated 10/21/2020 PHI Air Medical affidavit dated 12/21/2020 Smith County Healthcare Systems affidavit dated 4/13/2021 The Spine & Orthopedic Academic Research Institute affidavit dated 4/1/2021 Tyler Open MRI and Diagnostic Center affidavit dated 4/16/2021 BILLING RECORDS: 4 . A-Medical Advantage Healthcare Systems affidavit dated 4/13/2021 2 . Christus Mother Frances affidavit dated 9/2/2020 3 Elevate Health Clinics, LLC affidavit dated 3/15/2021 4 MRI Centers of Texas affidavit dated 10/21/2020 PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES— Page 1 PHI Air Medical affidavit dated 12/21/2020 Smith County Healthcare Systems affidavit dated 4/13/2021 The Spine & Orthopedic Academic Research Institute affidavit dated 4/1/2021 8 Trinity Clinic affidavit dated 3/15/2021 9. Tyler Open MRI and Diagnostic Center affidavit dated 4/16/2021 10.Uptown Radiology Associates affidavit dated 3/15/2021 RADIOLOGY IMAGING 1. Christus Mother Frances affidavit dated 4/6/2021 2. MRI Centers of Texas affidavit dated 3/21/2021 By copy of this notice, opposing counsel are notified that these affidavits and certified copies are being filed with the Court pursuant to TRE 902. The certified copies, records, and radiology corresponding to the enclosed affidavits will be kept in Plaintiffs counsel's office for use at trial. Opposing counsel have been previously provided with a copy of the affidavits and corresponding records/radiology and the certified copies listed above. PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES — Page 2 Respectfully submitted, WITHERITE LAW GROUP, PLLC By: /s/ Adewale Odetunde ADEWALE ODETUNDE State Bar No. 24088146 adewale.odetunde@witheritelaw.com SHELLY GRECO State Bar No. 24008168 shelly.greco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE | hereby certify that a true and correct copy of the foregoing has been forwarded to all counsel of record on this 12' day of May, 2021, pursuant to the Texas Rules of Civil Procedure. /s/ Adewale Odetunde Adewale Odetunde Sandra Liser Naman Howell Smith & Lee, PLLC 306 West 7th Street, Suite 405 Fort Worth Club Building Fort Worth, TX 76102-4911 J. Brantley Saunders Saunders, Walsh & Beard 6850 TPC Drive Suite 210 McKinney, TX 75070 PLAINTIFF'S NOTICE OF SERVICE AND FILING RECORD AFFIDAVITS AND CERTIFIED COPIES— Page 3 or Pe TEXAS DEPARTMENT OF PUBLIC SAFETY hr & “i §805 N LAMAR BLVD + BOX 4087 « AUSTIN, TEXAS 78773-0001 www. te xa. DRIVER | INSE DIVISION toe 512-424-2¢ 51 STEVEN C. McCRAW EN RSPANOL 512-424-7181 COMMISSION DIRECTOR STEVENP. MACH, CHAIRMAN FREEMAN F. MARTIN NELDA L. BLAIR RANDALL B. PRINCE STEVE H. STODGHILL JEOFF WILLIAMS DALE WAINWRIGHT OEPUTY DIRECTORS CERTIFIED ABSTRACT RECORD: 09/25/2020 . THIS TYPE OF RECORD WILL. REFLECT COMPLETION OF A DRIVING SAFETY COURSE. = THIS RECORD REFLECTS ENFORCEMENT ACTIONS, CONVICTIONS, AND CRASH INVOLVEMENTS THAT ARE ALLOWED TO BE DISPLAYED BY LAW. BROWN, JOSHUA NEIL 207 SOUTHRIDGE ST i Date of Birth: 11/07/1988 EDGEWOOD, TX 75117 Sex: MALE REPORT OF APPROVED DRIVER EDUCATION COURSE. Eye Color: GREEN DRIVER LICENSE AND COMMERCIAL LEARNERS PERMIT INFORMATION Driver License Number: License Type: DL License Class: Cc Date Originally Issued: 10/04/2005 Date Last Issued: 08/07/2020 Date of Expiration: 11/07/2025 Restrictions: NONE Endorsements: NONE STATUS INFORMATION Driver eligibility reflects @ person's oligibility to dive at the time this document was requested. Administrative Status details additional notes related to the person's record that do.not affect driving eligibility. Driver Eligibility: ELIGIBLE Administrative Status: NONE ENFORCEMENT ACTION HISTORY This section displays enforcement actions that may affect a person's eligibility rive. Additional information pertaining to any event related to the enforcement action can be found in the Event Section of this record. ACTION 1 PENDING ALR SUSPENSION - REFUSAL Begin Date: 09/24/2020 End Date: 03/22/2021 Notice Date: 08/15/2020 State: TX Hearing Request Date: 08/17/2020 Related Event(s): NONE ACTION 2 LIFTED DENIED RENEWAL - FAILURE TO APPEAR Begin Date: 11/08/2019 End Date: INDEFINITE Lift Date: 11/26/2019 Order Date: 11/10/2019 State: TX Related Event(s): NONE Page 1 |BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020 ACTION 3 LIFTED SR SUSPENSION - LIABILITY JUDGMENT Begin Date: 08/16/2012 End Date: INDEFINITE Lift Date: 04/18/2013 Order Date: 08/18/2012 State: TX Related Event(s) NONE ACTION 4 EXPIRED DEPT SUSPENSION - DWLI Begin Date: 08/26/2011 End Date: 02/18/2012 Notice Date: 07/14/2011 State: TX Related Event(s). NONE ACTION 5 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE Begin Date: 08/10/2011 End Date: INDEFINITE Lift Date: 08/11/2011 State: TX Related Event(s): EVENT 8 ACTION 6 LIFTED SUSPENDED - SURCHARGE DUE NO INS Begin Date: 08/10/2011 End Date: INDEFINITE Lift Date: 08/41/2011 State: ™ Related Event(s) EVENT9 ACTION 7 LIFTED SUSPENDED - SURCHARGE DUE NO INS Begin Date: 08/10/2014 End Date: INDEFINITE Lift Date: 08/41/2011 State: TX Related Event(s): EVENT 7. ACTION 8 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE Begin Date: 11/15/2010 End Date: INDEFINITE Lift Date: 02/03/2011 State: TX Related Event(s) EVENT 6 ACTION 9 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO DRIVER LICENSE Begin Date: 10/19/2010 End Date: INDEFINITE Lift Date: 02/03/2011 State: TX Related Event(s): EVENT 4 ACTION 10 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS Begin Date: 08/23/2010 End Date: INDEFINITE Lift Date: 02/03/2011 State: TX Related Event(s) EVENT 9 ACTION 11 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO DRIVER LICENSE Begin Date: 08/11/2010 End Date: INDEFINITE Lift Date: 02/03/2011 State: TX Page 2 LEROWN, JUSKIVA NEIL - CERTIFIED ABOITRAGT RECORD - U9/20/2020 Related Events): EVENT 8 ACTION 12 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS Begin Date: 08/14/2010 End Date: NDEFINITE Lift Date: 02/03/2011 State: TX Related Event(s) EVENT 7 ACTION 13 LIFTED SR SUSPENSION - NO LIABILITY INSURANCE Begin Date: 03/01/2010 End Date: INDEFINITE Lift Date: 01/19/2010 Order Date: 02/10/2010 State: TX Related Event(s) EVENT 7; EVENT 9; EVENT 12 ACTION 14 LIFTED SR SUSPENSION - NO LIABILITY INSURANCE Begin Date: 04/06/2009 End Date: INDEFINITE Lift Date: 04/06/2009 Order Date: 03/19/2009 State: T™X Related Event(s): EVENT 7 ACTION 15 LIFTED SUSPENDED - SURCHARGE DUE NO INS Begin Date: 04/09/2009 End Date: INDEFINITE Lift Date: 02/03/2009 State: T™ Related Event(s) NONE ACTION 16 LIFTED SUSPENDED - SURCHARGE DUE NO DRIVER LICENSE Begin Date: 09/42/2008 End Date: INDEFINITE Lift Date: 09/18/2008 State: 1™ Related Event(s) NONE ACTION 17 LIFTED DENIED RENEWAL - FAILURE TO APPEAR Begin Date: 07/23/2008 End Date: INDEFINITE Lift Date: 01/30/2009 State: TX Related Event(s) NONE ACTION 18 LIFTED SUSPENDED ~- SURCHARGE DUE NO INS Begin Date: 01/10/2008 End Date: INDEFINITE Lift Date: 02/26/2008 State: ™ Related Event(s) NONE ACTION 19 LIFTED SUSPENDED - DEFAULT INSTALLMENT AGREEMENT NO INS Begin Date: 08/13/2007 End Date: INDEFINITE Lift Date: 09/19/2007 State: TX Related Event(s) NONE ACTION 20 EXPIRED ALR SUSPENSION - UNDER 21 - FAILURE Begin Date: 07/14/2007 End Date: 09/11/2007 Notice Date: 06/04/2007 State: TX Related Event(s) NONE Page 3 |BROWN, JOSHUA NEIL_- CERTIFIED ABSTRACT RECORD - 09/25/2020 ACTION 21 LIFTED SUSPENDED - SURCHARGE DUE NO INS Begin Date: 01/10/2007 End Date: INDEFINITE Lift Date: 03/26/2007 State: TX Related Event(s): NONE ~ DRIVER RESPONSIBILITY PROGRAM (DRP) This section displays information relating the Driver Responsibility Program, tr Any su: S| ension action resulting from a notice will be referenced in the Enforcement Action History Section. SURCHARGE 1 CASE 12896746657323125600 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 2: 06/29/2011 Default Date: 08/10/2011 Complied Amnesty Date 08/11/2011 SURCHARGE 2 CASE 42463368999843923680 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 3: 06/29/2011 Default Date: 08/40/2011 Complied Amnesty Date: 08/41/2014 SURCHARGE 3 CASE 12012348355054916210 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 3: 06/29/2014 Default Date: 08/10/2011 Complied Amnesty Date: 08/11/2014 SURCHARGE 4 CASE 21447463574061649250 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 3: 10/04/2010 Complied Date: 06/23/2011 Default Date: 11/15/2010 Complied Amnesty Date: 06/28/2011 SURCHARGE 5 CASE 79392132408156008060 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 3: 08/09/2010 Complied Date: 06/23/2014 Installment Agreement Date: 09/08/2010 tnstallment Agreement Default Date: 40/19/2010 Complied Amnesty Date: 06/28/2011 SURCHARGE 6 CASE 71700982818196166300 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 2: 03/31/2010 Complied Date: 06/23/2011 installment Agreement Date: 05/03/2010 Installment Agreement Default Date: 08/11/2010 Complied Amnesty Date: 06/28/2011 SURCHARGE 7 CASE 55747732239893588380 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 2: 03/31/2010 Complied Date: 06/23/2011 Installment Agreement Date: 05/03/2010 Installment Agreement Default Date: 08/11/2010 Complied Amnesty Date: 06/28/2011 SURCHARGE 8 CASE 90900175975095442330 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 1: 02/11/2010 Complied Date: 06/23/2011 Installment Agreement Date: 02/19/2010 Installment Agreement Default Date: 08/23/2010 Complied Amnesty Date: 06/28/2014 SURCHARGE 9 CASE 14569142386068949380 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 2: 09/30/2009 Complied Date: 10/26/2009 SURCHARGE 10 CASE 3969688690327 2538040 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 2: 08/05/2009 Complied Date: 40/07/2009 SURCHARGE 11 CASE 23699084A13320090765 NO INSURANCE SURCHARGE NOTICE Page 4 | BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020 Notice Date - Year 1 03/27/2009 Complied Date: 07/21/2009 SURCHARGE 12 CASE 23699084A13420090765 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 1 03/27/2009 Complied Date: 06/15/2009 SURCHARGE 13 CASE 23699084A13320063197 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 3: 41/28/2008 Complied Date: 02/03/2009 Default Date: 01/09/2009 SURCHARGE 14 CASE 23699084A 13420082595 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 1 09/25/2008 Complied Date: 10/10/2008 SURCHARGE 15 CASE 23699084A13420082045 NO DRIVER LICENSE SURCHARGE NOTICE Notice Date - Year 4 08/01/2008 Complied Date: 09/18/2008 Default Date: 09/12/2008 SURCHARGE 16 CASE 23699084A 13320063196 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 2: 11/29/2007 Complied Date: 02/26/2008 Default Date: 01/10/2008 SURCHARGE 17 CASE 23699084A13320063195 NO INSURANCE SURCHARGE NOTICE Notice Date - Year 1: 11/29/2006 Complied Date: 09/19/2007 installment Agreement Date: 03/26/2007 Installment Agreement Default Date: 08/13/2007 Default Date: 01/10/2007 EVENT HISTORY This section displays information relating to convictions, crash involvement, safety courses completed, out-of-state surrendered license history and education program certificates. EVENT 1 CRASH NON-INJURY Accident Date 08/02/2014 Case Number: 0013969850 State: T™ County: ECTOR CMV: NO HAZMAT: NO Citation: CITATION ISSUED ~ NO DISPOSITION EVENT 2 CRASH NON-INJURY Accident Date: 04/10/2012 Gase Number: 0012653573 City: DALLAS State: TX CMV: NO HAZMAT: NO Citation: NO CITATION ISSUED. EVENT 3 CRASH NON-INJURY Accident Date: 04/03/2012 Case Number: 0012685963 City: KAUFMAN State: TX CMV: NO HAZMAT: NO Citation: NO CITATION ISSUED EVENT 4 CONVICTION EXPIRED DRIVER LICENSE Offense Date: 05/23/2008 Conviction Date: 06/26/2008 County: DALLAS State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No; JT0857209E CMV: NO HAZMAT: NO CDL: NO EVENT 5 CONVICTION SPEEDING Offense Date: 05/23/2008 Conviction Date: 06/26/2008 County: DALLAS Page 5 [BROWN, JOSHUA NEIL - CERTIFIED ABSTRACT RECORD - 09/25/2020 State: ™ Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No: JT0857208E CMV: NO HAZMAT: NO CDL: NO EVENT 6 CONVICTION EXPIRED DRIVER LICENSE Offense Date: 10/20/2007 Conviction Date: 11/07/2007 County: KAUFMAN State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No: CR0728254 CMV. NO HAZMAT: NO CDL: NO EVENT 7 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE Offense Date: 03/06/2007 Conviction Date: 08/04/2008 County: KAUFMAN State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No: CR071007 CMV: NO HAZMAT: NO CDL: NO EVENT 8 CONVICTION EXPIRED DRIVER LICENSE Offense Date: 03/06/2007 Conviction Date: 18/04/2008 County: KAUFMAN State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No:CRO71006 CMV: NO HAZMAT: NO CDL: NO EVENT 9 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE Offense Date: 42/04/2006 Conviction Date: 01/29/2009 County: KAUFMAN State: T™ Court Name Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No:CR063432 CMV. NO HAZMAT: NO CDL: NO EVENT 10 CONVICTION SPEEDING EQUAL TO OR GREATER THAN 10% ABOVE POSTED LIMIT Offense Date: 12/04/2006 Conviction Date: 01/29/2009 County: KAUFMAN State: TX Court Name: Justice of the Peace Court (offense = Texas Court) Case/Cause/Docket No:CR063431 CMV: NO HAZMAT: NO CDL: NO EVENT 14 CONVICTION SPEEDING EQUAL TO OR GREATER THAN 10% ABOVE POSTED LIMIT Offense Date: 07/19/2006 Conviction Date: 08/25/2006 City: BALCH SPRINGS State: TX Court Name: Municipal Court Page6 BROWN, JOSHUA NEIL_- CERTIFIED ABSTRACT RECORD - 09/25/2020 (offense = Texas Court) Case/Cause/Docket No: 060008926 CMV: NO HAZMAT: NO CDL: NO EVENT 12 CONVICTION NO MOTOR VEHICLE LIABILITY INSURANCE Offense Date: 06/17/2006 Conviction Date: 07/05/2006 City: SEAGOVILLE State: TX Court Name: Municipal Court (offense = Texas Court) Case/Cause/Docket No:0644135 CMV: NO HAZMAT. NO CDL: NO Pursuant to the authority contained in the Texas Rules of Evidence 902, Section 4, and Transportation Code, Section 621, |, Mimzie L. Dennis, do hereby certify that | am the custodian of driver records of the Driver License Division, Texas Department of Public Safety. The information contained herein is true and correct as taken from our official records. This !s to certify that notices of convictions for the traffic taw violations and incidents of motor vehicle accident involvement are received and recorded, along with the official action by the Department of Public Safety, in the computer records of JOSHUA NEIL BROWN. In Testimony Whereof, I hereunto set my hand and affix the Seal of the Department of Public Safety of the State of Texas on 09/25/2020. oF: Dyeae. ae aN! hi Ou Mimzle L. Dennis SHE Texas Department of Public Safety End of Record Page 7 MEDICAL RECORDS AFFIDAVIT OF A-MEDICAL ADVANTAGE HEALTHCARE SYSTEMS REGARDING PATIENT SHANTE WATSON STATE OF TEXAS § § COUNTY oF __ Dulas § BEFORE M' E, the undersigned authority, personally appeared Kosarod Aly , who, being by me duly sworn, deposed as follows: My name is a . |am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: | am the custodian of the records of A-Medical Advantage Healthcare Systems. Attached hereto are records from A-Medical Advantage Healthcare Systems regarding Shante Watson. These records are kept by A-Medical Advantage Healthcare Systems in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to trai it information thereof to be included in such record; and the record was made at or near the time event recorded or reasonably soon thereafter. The records attached hereto are the original _or-e up s of the original. — a a RECORDS SWORN TO AND SUBSCRIBED before me on the l 3 day of Ayal 20Ll. bn eg? NOTARY PUBLICAN AND FOR THE STATE OF TEXAS: ies Carry andes ose a NOTARY'S PRINTED NAME: nascfet eI aS comers itty, LISA M. CARRIZALSS e of Texas! ae % Notary Pub! lic, Stat ‘omm. Expires 02-18-2022 ‘of ‘S Notaryeae 1D 7806 ao Sa 5 Y COMMISSION EXPIRES: 2/78 /zoze Seam Sepa See RECORDS CUSTODIAN’S AFFIDAVIT AND DECLARATION {, the undersigned, herzhy ceitify that a duly authorized ciistodian of records for Christus EMS, and I have authority to certify said rece and copies thereof. her, I ereby certify that the copies of records attached hereto. are tue and accurate copies of the records of Shante A, Watson, and comprise ALL records and notes on Shaate A. Watson for ALL dates of treatient for ALE injuries, illnesses, incidents, or azeidents which Shante A. Watson received treatment at this facility. Thereby certify in commtiance with O.C.G A, $§ 24-8-863(6) and 24-9-902: 1) that these records: a) Were made at or near i time of the described acts, events, conditions, opinions, or diaghdses sét forth by or from information transmitted by a person with knowledge of such matters; ») Were kept in the course of your regularly conducted business activity; °) Were made as the regular practice of your regularly conducted business activity; and qd) Were made by or from information transmitted by a person with perscnal knowledge and a business diny to report. This 22 day of_ CNA A » 2020 ted 02 Records Custodian - oF Oh . ‘ hiclr? O 7 sk oa 7 RA SF ens) . PRINT NAME 2 2 S Notary 3 iden “gy sn to-and subscribed before me this “dt. day of ©) (2020 os \- ~ } 6 “ARY PUBLIC) My Ci [But 13 Expires: a AFFIDAVIT Relating to the medical records of _Shante A. Watson (patient name), for the date(s) of service __ 08/15/2020 to 10/27/2020 Before me, the undersigned authority, personally appeared Suzanne Yates (records custodian) who, being by me duly sworn, deposed as follows: My name is Suzanne Yates (records custodian). I am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: Tam the Custodian of Records for CHRISTUS Mother Frances Hospital — Tyle! (business name). Attached hereto are 0 273 _ page(s) and/or —_ CD(s) of medical records from CHRISTUS Mother Frances Hospital - Tyler (business name). These records are kept by said Custodian of Records in the regular.course of business, and it was in the regular course of business of CHRISTUS Mother Frances Hospital - Tyler (business name) for an employee or representative of said business with the knowledge of the act, event, condition, opinion, or diagnosis, recorded to make the record or transmit information thereof to be included in such record. The record was made at or near the time or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original(s). Affiant SWORN TO AND SUBSCRIBED before me on the 28 day of October 20_20_. APRIL BOHNE nue Behre NOTARY PUBLIC. Notary Public, State of Texas My Commission expires:_O. i Lf Ld vod STATE OF TEXAS 1D #12491352-1 { My Comm. Expires 07-18-2021 ICAL REC FIDAVIT OF ELEVATE HEALTH CLINICS, LLC REGARDING PATIENT SHANTE WATSON California STATE OF HexaS § COUNTY OF _Los Angeles § BEFORE ME, the undersigned authority, personally appeared Kerstin losue , who, being by me duly sworn, deposed as follows: My name Is __ Kerstin losue . Lam of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: c/o Atticus Medical Billing | am the custodian of the records of Elevate Health Clinics, LLC. Attached hereto are records from Elevate Clinics, LL oe shea ci 48 regarding Shante Watson. These records are kept by Elevate Health f business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. ‘ \ CUSTODIAN OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED before me onthe _15 _ day of March ,20_21 Ss ~ = nonin mi NOTAREPOBLIC iN FOR THE STATE OF CALIFORNIA: 5 Oe Le #5 i f COMM #2263804 Jennifer Nagy Angele Gounty O torn Notary Public ; NOTARY'S PRINTED NAME: sure Exp. Aug. 12, 2! Civtvetaraverat af ay Me ssl sles ins BARR we 550 MY COMMISSION EXPIRES: __ "262+ ¢| il ULL MEDICAL RECORDS AFFIDAVIT OF MRI CENTERS OF TEXAS REGARDING PATIENT _ SHANTE WATSON STATE OF TEXAS § COUNTY OF DALLAS § BEFORE ME, the undersigned authority, personally appeared GALDINA SALDANA , who, being by me duly sworn, deposed as follows: My name is GALDINA SALDANA . | am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: | am the custodian of the records of MRI CENTERS OF TEXAS. Attached hereto are records from MRI CENTERS OF TEXAS regarding SHANTE WATSON These records are kept by MRI CENTERS OF TEXAS in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original. RECORDS CLERK SWORN TO AND SUBSCRIBED before me on the 21ST day of OCTOBER 20,20 Gap? Aon NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS: RAQUEL ULLOA NOTARY'S PRINTED NAME: MY COMMISSION EXPIRES: _ 01/09/2024 p LER RAQUEL ULLOA é A) Notary 1D #132307314 My Commission Expires XE January9, 2024 MEDICAL RECORDS AFFIDAVIT OF PHI AIR MEDICAL REGARDING PATIENT SHANTE A. WATSON STATE OF eee § § COUNTY OF ¥ laricopa. § BEFORE ME. the undersigned authority, personally appeared ROCHEL 2 BOOTHE ae who, being by me duly sworn, deposed as follows: My name is ROCHEL BOOTHE tam of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated | am the custodian of the records of PHI Air Medical Attached hereto are records from PHI Air Medical regarding Shante A. Watson. These records are kept by PHI Air Medical in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original CUSTODIAN OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED before me on the <2/° day ot December_ 208? ZONA MY COMMISSION EXPIRES 9g 30RD CINDY ¢ GLOVE (COPA BOUNTY Commission # 652871 Expires September 20. MEDICAL RECORDS AFFIDAVIT OF SMITH COUNTY HEALTHCARE SYSTEMS REGARDING PATIENT SHANTE WATSON STATE OF TEXAS . § COUNTY OF _ Dallas. § B EFORE ME, the undersigned authority, personally appeared Alex Kosaroud , who, being by me duly sworn, deposed as follows: My name is oO | am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: 1 am the custodian of the records of Smith County Healthcare Systems. Attached hereto are records from Smith County Healthcare Systems regarding Shante Watson. These records are kept by Smith County Healthcare Systems in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit informatio fereof to be included in such record, and the record was made at or near the time of the event rec 'd or reasonably soon thereafter. The records attached hereto are the original or exact duplicates ie original. _ St -@SSTODIAN OF MEDICAL RECORDS SWORN TO AND SUBSCRIBED! ferme on tne 13 aay ot Ayal) 20 2/ hon > NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS bisa tariaales NOTARY'S PRINTED NAME: y COMMISSION ExPIRES:_Z/ 18) 2022. ee mes exes OE CRRA iy, VE ee Te) My syoror ws Me 9-18-2022 comm. & > 08888 Not “nk i gue atta sa MEDICAL RECORDS AFFIDAVIT OF THE SPINE & ORTHOPEDIC ACADEMIC RESEARCH INSITUTE REGARDING PATIENT STATE OF TEXAS county oF _\ Q0\\0) ERO 2 ‘ME. \} > _iwho,undersigned authority, being by me duly swom, personally deposed as follows: appeared U My name is Co (PQ | am of sound mind, capable of making this Affidavit, and personally acquainted with the facts herein stated: { am the custodian of the records of The Spine & Orthopedic Academic Research Institute. aoe eS are records from The Spine & Orthopedic Academic Research Institute regarding ANTE We These records are kept by The Spine & Orthopedic Academic Research In ite in the regular course of business, and it was in the regular course of business for an employee or representative with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof to be included in such record; and the record was made at or near the time of the event recorded or reasonably soon thereafter. The records attached hereto are the original or éxa panmsie of the original. U AIDA UW dgeTaDt OF sca RECORDS WO) SWORN TO AND SUBSCRIBED before me on the Ll day of ( Uy a / 20e\_ NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS: ASHLEY EUAINE TUCKERas c, State of Tex Muck tary Publi NOTARY'S PRINTED NAME. 5 10-30-2024 Comm. Expire e a7g040s Notary —pe12 MY COMMISSION EXPIRES: _| 0 | 90/94 > IEDICAL RECORDS AEFFIDA' OPEN MRI AND DIAGNOSTIC SENT | ER REGARDING FATIENT SHANT Ee WATS ON |‘ . STATE OF TEXAS § i t COUNTY OF &A, § ee a ME, th ie undersigned authority, personally ree