Anda di halaman 1dari 4

CASE 0:09-cv-01963-JRT-AJB Document 261 Filed 07/10/12 Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Spine Imaging MRI, L. L. C. , a Minnesota limited liability company, Plaintiff, v. Liberty Mutual Insurance Company, Massachusetts corporation, Wilson Mutual Insurance Company, a Wisconsin corporation, Allstate Insurance Company, an Illinois Corporation, and American Family Mutual Insurance Company, a Wisconsin corporation, Defendants, and Liberty Mutual Fire Insurance Company, Third Party Plaintiff, v. Eduardo Bullon, individually; Rafael Mendez, individually, Central Medical Clinic, LLC; Dr. Alfonso Morales, M. D. , individually; Northstar Radiology Corporation, P.A. ; Dr. William Ford, M. D. , individually and Dr. Hans Michael Castro, D. C. , individually, Third Party Defendants.

File No. : 09-cv-01963 JRT/AJB

AFFIDAVIT OF STEVEN P. POPE

I, Steven P. Pope, declare as follows:

CASE 0:09-cv-01963-JRT-AJB Document 261 Filed 07/10/12 Page 2 of 4

1. 2.

That I am one of the attorneys representing Plaintiffs in this case. That attached as Exhibit 1 is a true and correct redacted copies of excerpts of the deposition transcript of Eduardo Bullon which are not marked "Confidential";

3.

That attached as Exhibit 2 is a true and correct copy of Affidavit of William J. Ford, M.D;

4.

That attached as Exhibit 3 is a true and correct copy of Agreement between Advanced Imaging MRI of Minnesota and Consulting Radiologists(filed under seal);

5.

That attached as Exhibit 4 is a true and correct copy of a scan report from Advanced Imaging, Doc. No. SPINE0016683 (filed under seal);

6.

That attached as Exhibit 5 is a true and correct copy of Purchase Agreement (filed under seal);

7.

That attached as Exhibit 6 are true and correct copies of deposition transcript excerpts of Jennifer Hentges;

8.

That attached as Exhibit 7 are true and correct copies of deposition transcript excerpts of Hans Castro, M. D. ;

9.

That attached as Exhibit 8 is a true and correct copy of deposition transcript of David Vang;

10.

That attached as Exhibit 9 is a true and correct copy of deposition transcript of Jason Schmitt;

11.

That attached as Exhibit 10 is a true and correct copy of Plaintiff Spine Imaging MRI, L. L. C. 's Response to Defendant Allstate Insurance Company's First Request for Admissions;

12.

That attached as Exhibit 11 is a true and correct copy of Plaintiff Spine Imaging MRI, L. L. C. 's Answers to Defendant Allstate Insurance Company's First Set of Interrogatories (filed under seal);

13.

That attached as Exhibit 12 is a true and correct copy of Cervical Spine Protocol (filed under seal);

CASE 0:09-cv-01963-JRT-AJB Document 261 Filed 07/10/12 Page 3 of 4

14.

That attached as Exhibit 13 is a true and correct copy of document referred to as "Marketing Services Report";

15.

That attached as Exhibit 14 are true and correct copies of excerpts from deposition transcript of Alfonso Morales, M. D. ;

16.

That attached as Exhibit 15 are true and correct copies of excerpts from the deposition transcript of Anthony Anderson;

17.

That attached as Exhibit 16 are true and correct copies of excerpts from the deposition transcript of Hemi Minette;

18.

That attached as Exhibit 17 is a true and correct copy of Agreement for Radiology Interpretation Services (filed under seal);

19.

That attached as Exhibit 18 are true and correct copies of excerpts of Eduardo Bullon's deposition transcript marked "Confidential" (filed under seal);

20.

That attached as Exhibit 19 is a true and correct copy of bill for global services (filed under seal);

21.

That attached as Exhibit 20 is a true and correct copy of Affidavit of Scott R. Schultz, M.D. and

23.

That attached as Exhibit 22 is a true and correct copy of Spine Imaging Report (filed under seal).

That the above statements are true and correct to the best of my knowledge.

Dated: July 10, 2012

s/Steven P. Pope Steven P. Pope

Subscribed and sworn to before me this 10th day of July, 2012. s/Dacia L. Lenz Notary Public - Minnesota My commission expires January 31, 2015

CASE 0:09-cv-01963-JRT-AJB Document 261 Filed 07/10/12 Page 4 of 4