Weingarden, 375 Municipal Drive, Richardson, TX 75080; before a representative and duly authorized Notary Public for: Guyton Document Services.
Notice is fiirther given that request is hereby made as authorized under Rule 201 and 208, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be served on the witness to produce for inspection and photocopying the original(s) or a true and correct copy of any and all medical records, hospital records, emergency room records, reports, prescription records, patient questionnaires, patient histories, patient registration forms, patient information forms, patient profiles, any and all images of radiologic studies, including but not limited to, x-ray reports, pathology and cytology reports, schedules, writings, printings, drawings, graphs, charts, notes, typewritings, consent forms or other treatment authorizations, implantable medical device records, photographs, laboratory results, photographic negatives, motion pictures, tape recordings, videotapes or cassettes, computer records, disks or printouts, brochures, pamphlets, calendars, contracts, interoflice communications, telephone recordings, notices, letters, memoranda of telephone communications and insurance filings; and including any carbon, photographic, microfilm, or other type of copy of such items whether or not such copy is different from the original by reason of any markings, ‘additions, commentaries, revisions, deletions or substitutions and narratives or data compilations and any other notes, records, reports, memoranda, notes, correspondence, narratives and consultations in the possession, custody or control of said witness pertaining to Dreama Mae Pennington, AKA Guthrie and to turn all such records over to the officer authorized to take this deposition so that photographic reproduction of same may be made and attached to said deposition.
Attorney for Defendant Bar# 10933700 I hereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition by Written Questions was mailed to the respective parties and/or attorneys of records by certified mail, return receipt requested, or hand delivered or transmitted by telephone facsimile.
Box 4651 Houston, TX 77210 Re: Dreama Pennington vs. Dow Corning Corp. No: 92-25394EC, In the 334th District Court in and for Harris County, Texas Records Pertaining to: Dreama Mae Pennington, AKA Guthrie; Order No. 33380 To Whom It May Concern: Enclosed please find a copy of Notice of Intention to Take Deposition by Written Questions in regard to the above styled and numbered cause.