Formal Request for Production of HCA Staff Names, Bios, Home Addresses (as Required for Any Subpoenas)

Mark Burke, Plaintiff files this request from KPH – Consolidation Inc., DBA HCA Houston Healthcare Kingwood, a domestic For-Profit Corporation, Defendant herein;

REQUEST FOR PRODUCTION

Plaintiff formally requests herein, per Tex. R. Civ. P., Defendant’s compliance to provide “HCA staff”[1] at HCA Kingwood Hospital who interacted with Plaintiff during his visit, or who were involved in the care of Plaintiff but did not physically participate or meet Plaintiff (as a patient), or who were involved in the post-discharge complaint(s) as submitted to Defendant’s.

Assistance by Plaintiff: Known HCA Staff

Plaintiff has reviewed the MyHealthOne Portal and whilst the following list is not exhaustive and Defendant is responsible for ‘filling in any blanks’, these known HCA Staff qualify as part of this request.

Relevant Doctors visiting South Wing, RM 376

Mowla, Mohammed R  MD

Avila Castillo, Daniel  MD R1

Wong, Mike  MD R1

Chung, Randy  MD

Ehsan, Sana  MD

Emergency Room (ER)

Dionne, Amy M  APRNNP

Tatineni, Lakshmi  MD R2

And Dr. Barton James MD

Unknown; Ilyas Muzna A, MD

Obviously, the “Referred Self, Referring” individuals need to be identified and information provided by Defendant.

Nurses and Security Guards who Threatened Eviction

On the 10^th of August, 2023, a nurse along with a new trainee arrived at Room 376, within an hour of Mark Burke’s transfer from ER to the South Wing. Plaintiff requests the same information about these two members of HCA Staff along with the subsequent cackle of Nurses and Security Guards who charged into Plaintiff’s Room while he was in need of  urgent medical care and rather than timely attend to the requests by family and Plaintiff, the charge nurse refused, and threatened to evict Patient and visiting parents as outlined in Plaintiff’s original complaint and where Plaintiff’s own video and photos can help identify some of the HCA Staff present;

Video link; https://kingwooddr.com/wp-content/uploads/2022/08/kingwoodnurseswithsecurity1.mp4

Director of Community and Public Relations, Ms. Devon Alexander

Plaintiff also requests information regarding Ms Alexander, who may or may not still be employed by Defendant, but Defendant will still have her information, as requested.

Post Discharge Complaint(s)

The complaint(s) and Spoilation Letter(s) by Plaintiff post-discharge were signed by John or Jane Doe(s). Plaintiff seeks full information as to the HCA Staff assigned to these complaint(s) and HCA Staff involved in providing information for the complaint, including the footage of the video surveillance.

Appointment of Serpe Andrews, PLLC, as Counsel for Defendant

The request requires the same information pertaining to who at HCA entered into a binding agreement to assign Serpe Andrews, PLLC on this case, when the contract was agreed, signed and related information which is necessary due to Plaintiff’s allegations in the complaint about the unethical behavior of Ms. Nicole Andrews, Partner at Serpe Andrews, PLLC. Note; Engagement letters do not fall under the scope of attorney-client privilege as previously highlighted in pleadings before this court.

Voluntary Disclosure Requests Snubbed by Defendant

Plaintiff reached out to Defendant multiple times via HCA Lawyers but these lawyers continue to be unethical, and refuse to acknowledge or respond to any emails or letters which Plaintiff submits, asking for voluntary disclosure of this information. See; Exhibit “Email Reminder to HCA Lawyers re Voluntary Discovery, Jan. 12, 2023” and Exhibit “Letter to SA Discovery Dec 27 2022”.

Home Addresses Essential for Compliance with Subpoena Laws

The request for home addresses is for compliance with any subpoena requests, which specifically require that the person or persons live in Harris County and within a 150 mile radius. For example, apparently Dr. Avila Castillo, Daniel MD R1 allegedly works for HCA in Harris County, but his Linkedin profile shows that he is in Austin, Texas, which would be around 162 or so miles from Houston, thus could quickly quash any subpoena. See; Exhibit “Avila Castillo, Daniel MD R1, Linkedin Screenshot at Jan. 10, 2023”

RESPECTFULLY submitted this 13th day of January, 2023.