WomINGUPTHE Ca.sn & DnMAND Pn'craGE 2014 UT Can WnPcr CLE J. Luke Dow Lew Oprrce or J. LurP Dow 2901-C Bee Cave Road Austin, Texas 78746 Telephone: (512) 480-9502 Facsimile: (512) 480-9508 Email: luke@lukedow.com Website: www.lukedow.com
This paper is intended to provide tips and guidelines in working up your personal i.rj,rry cases from intake through the demand package in order to maximize pre-suit settlement value. Even if the case is not settled and you end up in a lawsuit, you will at least have completed some of the necessary legwork in getting your case ready for trial. So either way, it makes sense to be thorough on the front end of your case. INTAKE Most people who end up in your office have never been through an accident or dealt with an insurance company. Some have no idea what to expect and many have unrealistic expectations. In any event, they are looking to you for guidance and help. Before meeting with a potential new client, I try to get them to send me as much information as possible so that I can review it before the meeting. This allows me to focus more on them while they are sitting in front of me rather than reading through documents. Having your paralegal or someone on your staff in the initial meeting gives him or her the opportunity to learn the case from the outset. Your paralegal will also get to know the person with whom they will be working. My paralegal usually takes better notes than I do and it gives me another set of eyes in evaluating the potential client and his/her case. Finally, it allows the client to get to know my paralegal and develop a level of trust with her. Although I try to work directly with the client after the initial meeting, I f,rnd that the client is more comfortable dealing with my paralegal when they've previously met in person. At the initial meeting, we try to gather as much information as possible. This includes witness information, the police report, list of treating doctors, lost wage information, photographs, property damage estimates, insurance information and claim numbers, past Page2
injuries, past claims, criminal history, health insurance info, etc. You cannot have too much information! In the intake, I am also evaluating the potential new client and her case. Over time I've learned that declining a case about which I have reservation(s) is good practice. If you are hesitant about a client or case, this reservation will probably not improve over time. If you decline the case, it is good practice to follow up with a rejection letter. Clrnxr Exppctarroxs I always want to make sure that the client and I are on the same page. To that end, I have a very frank discussion at the outset about their expectations regarding VALUE and TIME. Most people want to know "how much is my case worth" and "how long will it take". If you answer the first question in the initial meeting, good luck explaining that later on. Rather, I make sure that they understand there is no way to value the case at such an early stage and that any attempt to do so would be speculative at best and malpractice at worst. I try to explain the reality of injury cases in Texas and give them examples such as "paid vs. incurred" and medical malpractice caps (even if it's not a medical malpractice case). I avoid getting on my political soapbox and simply point out the reality of tort law in Texas. The point of this is to gauge their expectations and determine if I can meet those expectations. If I sense that I can never meet those expectations, I reject the case. We've all heard something like "my friend's cousin got rear ended in a parking lot, went to his chiropractor a few times, and his attorney got him $ 1 00k!" That' s great - feel free to go hire that lawyer. At best, these types of people will be unmanageable clients if their expectations remain unchecked. In my humble opinion, life's too short and money's not everything. Page 3
I try to outline the claims process and explain that it will take time. First, my office will not order the medicals until treatment is completed, which is 100% up to the medical professionals. Even when this is done it is at least a matter of months before we are in a position to settle. I explain that my goal is to get the insurance company to their very best offer and that only then can an informed decision be made on whether to take the offer or file suit. I let them know that if suit is filed, it could very well take over a year and possibly multiple years depending on the complexity of the case and/or injuries. I explain that I will do everything in my powff to get the case resolved as efficiently and effectively as possible, but I never guarantee a result or a timeline. I also try to follow this meeting up with a letter outlining the process, a sample of which is included in this paper. ClrrNt Pnrparurrox As we all know, medical non-compliance and gaps in treatment can cripple a case. I impress upon the client that every move they make, or fail to make, will be scrutinized and questioned. This is especially true with not showing up for appointments and not following medical orders. Any failure to follow medical advice and keep appointments is detrimental. If they simply can't avoid missing an appointment, they need to contact the provider beforehand and explain the reason. The client also needs to understand that from the moment the accident occurred through a verdict, they are susceptible to being monitored. This includes social media and blogging. I certainly research the potential defendant and they should expect the same from the insurance company and its attorneys. I urge them to exercise discretion and common sense in posting any information on Facebook, Twitter, etc... Page 4
Assuming I've decided to take the case during the initial meeting, I have the client sign a fee agreement, medical authorization and give them a lost wage verification form to take with them. I also have a medical provider list which is kept in the file. A11 of these forms are included in this paper. Finally, I tell the client to call/email my paralegal or myself with any questions and/or updates, but to certainly let us know when they have been released from treatment. OPENING AND WORKING THE FILE Polrcn Rpponr & Wlrxnss STATEMENTS Immediately after the initial meeting (assuming I've been retained), my paralegal and I go through a "client checklist" and assign action items between us. We try to order the police report the same day if the client doesn't already have it. If we are obtaining the report, we order a certified copy so that it is admissible if the case doesn't settle. Getting witness statements quickly is also important. Witnesses may move, die, forget, etc... Better to get this information established early. Obviously, we speak to the witnesses first and ensure that they are willing to cooperate and are favorable to us. The more things my office does on the front end, the less likely it will slip through the cracks. In addition to explaining how an accident occurred, witnesses may be able to tell you if the other person was using a cell phone or otherwise distracted. Besides witnesses to the accident, get a list of people who will later be able to testify regarding how the accident has affected the client's daily activities, work, hobbies, etc... These folks may eventually provide valuable evidence of the client's pain and impairment. This information may or may not be used in a demand package, but will prove invaluable at trial. Page 5
LBrrBns or RtpnnsENTATIoN It is best to fax a letter of representation out to the liability carrier the same day so that they no longer try to contact the client. Conversely, the client needs to know not to contact the liability carrier. I also set up a sub-file for UMAJIM and PIP and send letters of representation to these carriers. In the notice, I demand written rejection of UMfuIM and PIP benefits. Lruxs/SunRoGATIoN I find it helpful to keep certain items segregated from the rest of the file. I do this by creating a sub-file within the main file. This is especially true with liens and subrogation claims. I don't want to settle a case and disburse the money only to leam that a letter of protection was buried in the correspondence file. Also, it will save time to set up the Medicare and/or Medicaid claims early rather than waiting until the case settles. Further, you need this information to establish "paid vs. incurred". Set up the Medicare and Medicaid claims early. When setting up the Medicare claim, send the fee agreement and the client's HIPAA authorization with the initial letter. Also include a detailed list of the client's injuries. Both Medicare and Medicaid's information is included in this paper' Mnorcll, Rrconos & BIlls Once the client is finished with treatment, it's time to order the medical information. I emphasize that it is the client's responsibility to let me know when treatment has ended. For several reasons, I order medical bills and records in admissible form at this early stage. First, the adjuster will know that you intend to file suit in the event that the case is not resolved. Second, if you end up filing suit, you can file your affidavits early and trigger the Page 6
defendant's deadline to file contraverting affidavits to your bills sooner rather than later. Third, it prevents you from having to order the medicals twice in the event the case doesn't settle without a lawsuit. Finally, the affidavits spell out the "paid vs. incurred" figures that you will ultimately submit to a jury. N,lRRarryBs In some cases, you may need to obtain medical information that is not included in the records or bills. For instance, if you are asserting a claim for future medicals, this most likely will not be adequately addressed in your client's past medical records or bills. In this situation, you will need to have at least one narrative completed by a physician to support the claim. Otherwise, this element of damages will not be considered by the adjuster. The same goes for future lost wages if your client can't work but has no documentation to that effect' A request for a narrative is included in this paper. PHorocRapus Pictures of property damage and injuries are very compelling and may increase the value of your client's case in some circumstances. Assuming the photos help the case, they obviously need to be a part of the demand package. If your client has a visible injury, have them take photos of the injury at its early stages and as it improves where it is appropriate. This is especially true if you are making a claim for disfigurement. It is also useful to show objective injury, pain and suffering and possibly impairment. GexnRq.L You can also conduct a background check of the other driver to determine his criminal background and driving offenses or suspended license. A preliminary check can be made on PageT
www.publicdata.com. A more comprehensive background check may necessitate an investigator. If a commercial vehicle was involved, obtain the DOT inspection report' your client may have additional medical bills such as prescriptions or deductibles that are not readily apparent from the medical records. Your client's laptop may have been destroyed in the accident. you can gather most of this information directly from your client' Before filing a lawsuit, you typically don't know the other party's limits of liability or whether they have an umbrella policy. I'm aware of at least one service that assists in finding this information. A good investigator may also find it' When it comes to dealing with the adjuster, I try to be courteous and friendly and avoid hostility. I try to find the things upon which we agree and establish some conlmon ground' When we disagree on an issue, I try to address it without being ugly or rude' If we are unable to settle the case and I need to file a lawsuit, I send a courtesy copy of the petition to the adjuster. I don't believe that treating the adjuster poorly or trying to bully them will advance my client's cause. In fact, I believe that it may harm my client's cause' I try to advance my client's interests rather than my own ego. When it comes to giving a recorded statement, I almost always decline. However, there are a few situations in which I will allow it. For instance, if the case needs an extra push and I,ve got a great client, I will consider it. In those rare situations, I get an agreement beforehand that the insurance company will provide a copy of the statement (either recorded or transcribed) immediately afterwards. I also prepare my client just as if we were preparing for a deposition. I know that this goes against the grain of conventional wisdom, but I will occasionally allow it under these limited circumstances. If the client is adequately prepared and I secure a transcript, I'm not worried about issues of consistency in future testimony' Page 8
THE DEMAND PACKAGE When the time comes to send the demand, visit with the client about the amount of the demand given the facts of the case, the injuries and the information that has been obtained. Obtain their consent to the amount of the initial demand, but also explain that the demand is just a starting point. Explain the negotiation process and that the goal is to get the best offer possible and that the first offer is rarely the last. I let them know that once I get the "best" offer, I will break it down completely to determine their net recovery. That way they can make an informed decision about settling or filing suit. If it's a clear Stowers situation, I may explain that unless the demand is met, we will simply file a lawsuit. In the initial demand package, try to be reasonable and not overreach. For instance, if the client has $15,000.00 in medicals and has fully recovered from her injuries, and there are no aggravating circumstances, don't demand $500,000.00. t think that sets false expectations for the client and makes you seem unreasonable or even incompetent to the adjuster. This scenario would most likely result in a no-offer or an offer of $250.00, which will in turn upset the client. Why stir the pot unnecessarily? Further, if it is notastowers situation, don't include Stowers language in the demand. Again, this will do nothing to advance the client's case and will only hurt your credibility. However, if the case is a Stowers situation, make sure that all of the Stowers requirements are met. I have included what I believe to be the appropriate Stowers language in this paper. In your letter, first establish liability with the police report and witness statements. If there is a question about liability, address it early. If the client bears some percentage of Page 9
responsibility, acknowledge this fact. This approach may go against every fabric of your being, but I believe it establishes credibility. The demand letter is not admissible anyway. Once you've discussed liability, go through your client's damages. Include medical records, bills, lost wage verification, photographs and narratives. If the case merits a life care plan, by all means include it. The adjuster's job is to close files promptly and efficiently. Try to help them reach their best offer by providing them with the information that enables them to do so. If you are able to settle without filing a lawsuit, that's great. If you are unable to settle, wish the adjuster well and file suit. You will most likely deal with this person again in the future, so try to establish and maintain a good working relationship' Good luck and I hope that this paper is of some benefit to you! ATTACHMENTS TO THIS PAPER: New CltpNT LIST Fee AcnepMENT Meprcel AurHoRIzRttoN Losr WecE VERIFICATIoN FoRM Meorcel PRovroeR Ltsr NBw CIIeNT LETTER Meorcene CoNrecr INno Meorcenn ConnespoNDENCE Coven Sneer Mporcerp CoNrecr INro Meorcnr Brr-rNc Aprroevrr (Tex. Crv PRacr & Rpv Cooe SEcrtoN 18.02 tno Escoaooo) MEprcel Reconos Arrtonvtr (Texas Rules op EvloeNcE 902(10)(s)) NeRRertve Rreuesr Srowoas LaNcuncr Page 10
NEW CLIENT CHECKLIST Fee Agreement Medical Authorization Lost Wage Verification Client Info Client letter Client List (w/ DOB) Police Report Photos LOR Medicals il Affidavits Medicals dout Affi davits LOP Demand to be sent File Suit i No Demand Medicare/Medicaid Notice Liens/Subrogation PIP UMruIM
FEE AGREEMENT If no settlement is obtained, client will not owe a legal fee or expenses. CLIENT AGE PARENT/REPRE SENTATIVE STREET ADDRESS CITY, STATE, ZIP PHONE: Home: Law Office of J. Luke Dow 2901 Bee Cave Road, Box C Austin, Texas 78746 512-480-9502 s I 2-480-9508 luke@lukedow.com PHONE: Work/CelUPager: CASE TYPE: Injured person is: Adult, signing for self Disabled adult or minor, signed by parent/representative Deceased, signed by authorized representative LEGAL REPRESENTATION. Client hires the Law office of J. Luke Dow (JLD) to pursue a clalm for injuries *dd"@nceorotherlegalbreach.clientauthorizesjldtopursueavailablesourcesof recovery * no deems n"""riury. Client ugr..r that JLD may associate additional lawyers/firms to assist with this case and Client agrees to thosharing of f."r between lawyers. Client understands the terms herein apply to other lawyers associated on this case and that association of other lawyers or law firms does not increase the amount of the attorney fee due to lawyers on successful resolution of the claim. COOPERATION. Client agrees to be available for consultation, investigation, deposition, trial preparation, *a ao necessary work as JLD directs and do nothing to impair the value of the case. JLD agrees to use his best effort and skill in pursuing this case but do not guarantee a specific result. Client appoints JLD as his/her afforneys-in-fact to p."r"rrt claims and/or endorse checks or drafts representing settlement or judgment proceeds to expedite disbursement. 33 l/3% LEGAL FEE If no settlement is obtained, client will not owe a legal fee or expenses. If JLD obtains settlement *..ou"ry for Client, Client will pay to JLD thiny-three percent (33 ll3%) of the total gross recovery. Expenses wiit Ue paid out of client's recovery. If the case cannot be resolved short of trial, then the fee increases to forty percent (40%) of the total gross recovery. CASE EXPENSES & AUTHORIZATION. JLD will not ask client for expense money during the t unatirg of th..a... Cus..osts and expenses will be advanced by JLD. Examples of typical expenses include court filing fees, investigation, court reporters, medical records, interest on any money JLD bonows for expenses, ixpert witness fees, air fare,.tr. tf a recovery is obtained, Client will reimburse JLD for these expenses from Client's share of the total recovery. TERMINATION OF THIS AGREEMENT. If this agreement is terminated before the case is resolved, client g*"r JLD. tt* ugai.rrt u.ry subsequent recovery as allowed by Texas law. JLD may withdraw from iepresentation of Client if they determine prosecution of the claim is not practicable.
MISCELLANEOUS. Client has read this agreement (or has had it read to himlher) and agrees to be bound by these terms. Any modifications in the terms of this agreement shall be typewritten or handwritten in the margin below and initialed by both parties. LIMITED POWER OF ATTORNEY. JLD is hereby granted a limited power of attomey so that JLD may have full authority to prepare, fully execute, sign and file all legal instruments, pleadings, drafts, authorizations, and PIP/JvledPay applications as shall be reasonable and necessary to complete JLD's representation including Client's personal injury and first party insurance claims as fully as Client could do so in person. This expressly includes the right to sign Client's name to insurance company drafts or checks or any other negotiable instruments proferred on behalf of defendant herein in full or partial settlement of Client's personal injury and first party insurance claims. LAW OFFICE OF J. LUKE DOW Date I CLIENT OT CLIENT'S REPRESENTATIVE Date _l I
I hereby authorize,,to disclose my individual identifia6lehealthinfoffihichmayincludeinformationasdescribedbelow, which may include information concerning communicable diseases as such as Human Immunodeficiency Virus 1,.HIV,') and Acquired lmmune beficiency Syndrome ("AIDS"), mental illness (except for psychoiherapy notes), chemical or alcohol dependency, laboratory test results, medical history, treatment, o, ury other such related information. I undeistand that this authorization is voluntary and I may refuse to sign inis information. I further understand that my health care and the payment of my health care will not be affected if I do not sign this form. I understand that this information may be subject to redisclosure and no longer protected. I understand that if the recipient authorized to receive the information is not a covered entity, e.g. insurance company or health care provider, the release information may no longer be protected by federal and state privacy regulations. Patient Name Date of Birth Social Security Number Date(s) of Service (if known) Description of information to be released (check all EFace Sheet trradiology Repofis EDischarge Summary Elaboratory Reports trhistory & Physical EConsultation Reports EOperative RePorts EPathology Reports EDiagnostic RePorts The purpose of the disclosure is for the following: tr Patient Request: (type of disclosure) Attorney The information described herein will be sent to the following address: that apply) ORadiology Films (lmaging DePt.) OBilling Records (Patient Financial Services) OEmergency Room EOther: Name Address I understand that this authorization will expire 180 days from otherwise specifu. I desire this authorization to be in effect until the date of this authorization unless I I further understand that I may revoke this authorization at any time by notifuing J. Luke Dow at 2901 Bee Cave Road, Box C, Austin, t"*u, 78746,and the above stated health care provider in writing. I also understand that the written revocation must be signed and dated with a date that is later than the date of this authorization. The revocation will not affect any actions taken before the receipt of the written revocation' Signature Date Printed Name of Patient's Representative A COPY OF THIS AUTHORIZATION SHALL BE VALID AS THE ORIGINAL
LOST WAGE VERIFICATION Employer: Address: Phone: Employee: Occupation/Title: Length of Employ: Hours per week: Wage: per Hour/Week/Month/Year (Circle One) Total time missed: Total Lost Wages: Other lost benefits: Employer Printed Name: Employer Signature: Employer Title:
MEDICAL PROVIDER LIST \' clatm No: o4osi2o431i2 Please list all of the ohvsicians that vou are curre with Name: Address: Name: Address: Phone: Phone: Name: Address: Name: Address: Phone: Phone: Name: Address: Name: Address: Phone: Phone: Name: Address: Name: Address: Phone: Phone: Name: Address: Name: Address: Phone: Phone:
Law OpptcP or J. LurB Dow ATTORNEY AT LAW THE COMMISSIONERS HOUSE AT HERITAGE SQUARE 29Ol BPP.CnvE RoeD, Box C AUSTIN, TEXAS 78746 Board Certifred - Personal Injury Trial Law Texas Board of Legal Specialization Telephone: (512) 480-9502 Facsimile: (512)480-9508 June28,2014 Mr. xxxxxxxxxxxxxx 123 Road Austin, Texas 18664 Re: Claim No.: Our Client: Your Insured: Date of Loss: xxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxx Dear xxxxx: I enjoyed visiting with you and appreciate the opportunity to represent you in the above_referenced matter.- Although I will contact you with updates as yow case progresses, prease feel free to contact me at any time with questions, additional information, etc..., either via phone or email, which is luie@lukedow.com. My website can be accessed at www.lukedow.com. Most people are unfamiliar with the claims/litigation process in general, and more specifically with the nuances,urrorrnding a personal injury caje' Let me therefore take this opportunity to give you a general outline of what to expect' CLAIMS PROCESS This is the phase of the case before a lawsuit is filed, where both sides are attempting to settle the case without expending the time and expense of litigation. If a_ claim has not already been set up with the insurance company or other appropriate party, I witl take-care of this' Either way, I will send a letter of represeniation to the carrier once I've been retained by you' Once you finish any and all medical treatment you ale receiving, please call me to let me know that you've been released from treatment. This is very important as it is the only way I'll know to begin ordering your medical records and bils. - once I've received all records and bills, and any additional information such as lost *ages you've incurred, photographs, property damage' etc^"' I will prepare a demand package to be sent to the insurance company' During this phase of the case, my goal is to g.t th" verf best offer that the other side is willing to make' Once this is done' I,ll be able to give you a breakdown based on the offer. If you choose to reject the offer, the next
step is to file a lawsuit and begin the litigation process. This is a much more formal process and is governed by the Texas Rules-of Civil Procedure and the Texas Rules of Evidence' LITIGATION Once a lawsuit is filed, I,ll be dealing with a lalvyer who represents the defendant as opposed to the claims adjuster. Dr;t;; lalsu.it,.both sides typically exchange written discovery which will require your assistince. This is important becau.se there are strict times within which discovery needs ao *.*.i"j, and the failure to do so will normally result in the waiver of objectior. io.*. at best, ani dismis'al of your case at worst' Therefore' it is imperative that you cooperate with my office in answering the discovery questions' DepositionsusuallyfollowthewrittendiscoveryifnecessarY,andthenamediationin which the parties attempt to settle the case. If the case doesn't settle at the mediation, the last step is a trial before a judge and/or jury. fo g"t u tu" worked up and tried to a.jury will usually take one (1) year or more, depending on the pa?iculars of the case' Unless one side files an appeal' the jury verdict will be the ending point of the case' Again, this is the general course of events'.some cases may settle quickly without discovery or depositions, and,oln.,*y-tui.,rurt*tially longer' Although most cases settle before trial, a r.uti p"r."ntage will require trial to reach conclusion. In any event, I appreciate the opportunity- to represent you and look forward to working with you. I hope the foregoing gives Vir.or. idea of what to Lxpect. Nevertheless' feel free to contact me at any time with questions you may have' Sincerely, J. Luke Dow
MEDICARE To set up claim: 85s-798-2627 NGHP PO Box 138832 Oklahoma City, Oklahoma 73113 Fax (405) 869-3309 http :i/go.cms. gov/attorney SEND FEE AGREEMENT AND HIPAA AUTHORIZATION
cg.rm &n.llb md Racovry NGHP Correspondence Cover Sheet Beneficiary's Name HIC#: Date of lncident: Case ID#:.(can be found on Rights and Responsibilities leuer) This cover sheet is for your use when mailing or faxing in correspondence to the Benefits Coordination & Recovery Center (BCRC). Please retain a COPY of this cover sheet for any future correspondence. The information above will ensure accuracy when handling your case documentation. Please indicate the type of correspondence you are submitting to the BCRC to facilitate routing. Check all that apply: tr Check I Settlement information! Retainer agreement or other authorization documentation E Other Note: A Conditional Payment Letter is sent automatically, as soon as the information is available. Separate requests for initial Conditional Payment Amounts will not make Conditional Payment information available sooner. In order to accurately associate claims to your case, please include a description of the injury. (i.e.: Knee, Physical Therapy, Slip and Fall, Lumbar Injury...) Submit correspondence to the BCRC address listed below: Liability Insurance, No-Fault Insurance, Workers' Compensation : NGHP PO Box 138832 oklahoma City, OK 731 l3
MEDICAID TMHP PO Box 202948 Austin, Texas 7 8720-2948 Fax (512) 514-4225
MEDICAL BILLING RECORDS AFFIDAVIT (ANY AND ALL RECORDS FROM 0410312014 TO THE PRESENT) RECORDS PERTAINING TO: XXXXX; DOB: XXXX; SSN. *** THE STATE OF TEXAS, COUNTY OF TRAVIS BEFORE ME the undersigned authority, personally appeared who being by me duly sworn, deposed as follows:. I am of sound mind, capable of making this My name is affidavit, and personally acquainted with the facts stated herein. I am the person who provided these services or the custodian of records showing the services provided and charges made. Attached hereto and incorporated herein by reference is an itemized statement of the services provided to NETWORK/UMC@BRACKENRIDGE for the date(s) of service from to The total amount charged for these services is $ The total amount paid as of this date is $ The total amount unpaid but still owed as of this date is $-. -. At SETON HEALTHCARE The amounts paid and/or unpaid but still owed for the services set forth were reasonable at the time and place the services were provided, and the services were necessary for the treatment of "The attached documents are kept by me or someone under my supervision in the regular course of business, and it was the regular course of business of myself or an employee or representative of myself with knowledge of the act, event, condition, opinion, or diagnosis reiorded 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 or reasonably soon thereafter. The records attached hereto are the original or exact duplicates of the original." AFFIANT SWORN TO AND SUBSCRIBED before me on this,2014. day of NOTARY PUBLIC, State of TEXAS My Commission Expires Print Name
MEDICAL RE,CORDS AFFIDAVIT (ANY AND ALL RECORDS FROM 0410312014 To THE PRESENT) RECORDS PERTAINING TO: JOHN DOE; DOB: ; SSN: *** THE STATE OF TEXAS, COUNTY OF TRAVIS BEFORE ME the undersigned authority, personally appeared who being by me duly sworn, deposed as follows: My name is. I am of sound mind, capable of making this affidavit, and personally acquainted with the facts stated herein. I am the custodian of records of SETON HEALTHCARE SYSTEMruMC @ BRACKENRIDGE HOSPITAL. Attached hereto are of records from SETON HEALTHCARE 5y5rEM/UMC@BRACKENRTDGE HOSPITAL. These pages of records are kept by SETON HEALTHCARE SYSTEMruMC@BRACKENRIDGE -pages HOSpITAL in the regular course of business, and it was in the regular course of business of SETON HEALTHCARE SYSTEM/UMC @ BRACKENRIDGE HOSPITAL fot AN employee or representative of SETON HEALTHCARE SYSTEM/UMC@BRACKENRIDGE HOSPITAL, 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 records; and 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' AFFIANT SWORN TO AND SUBSCRIBED before 2014. me on this day of NOTARY PUBLIC, State of TEXAS PrintName My Commission ExPires