Government’s Witness List – Page 1 of 14

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

UNITED STATES OF AMERICA

v.

CRIMINAL NO. 3:22-CR-378-N

RAYNALDO RIVERA ORTIZ, JR. 

GOVERNMENT’S WITNESS LIST

The United States of America files this Witness List:

Probable Witnesses

T.Y.1 She will testify to events leading up to and through her surgery 

on August 4, 2022 at Baylor Scott & White Surgicare North 

Dallas, including the complications, her recovery, and her

current health.

J.E. He will testify to events leading up to and through his surgery 

on August 9, 2022 at Baylor Scott & White Surgicare North 

Dallas, including the complications, his recovery, and his

current health.

K.P. She will testify to events leading up to and through her surgeries 

on August 18, 2022 and August 19, 2022 at Baylor Scott & 

White Surgicare North Dallas, including the complications, her 

recovery, and her current health.

J.A. He will testify to events leading up to and through his surgery 

on August 24, 2022 at Baylor Scott & White Surgicare North 

Dallas, including the complications, his recovery, and his

current health.

R.A. She will testify to events leading up to and through J.A.’s 

surgery on August 24, 2022 at Baylor Scott & White Surgicare 

North Dallas, including the complications, his recovery, and 

current health.

J.K. He will testify to the events leading up to and following the 

death of M.K. on June 21, 2022, including her use of an IV bag 

on the day of her death.

1 The victims and their family members in the case are identified by initials. Additionally, the 

government has not provided certain home addresses of victims and witnesses to protect those 

individuals’ privacy interests. The government has provided the names and addresses to the defendant.

 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 1 of 14 PageID 1094
Government’s Witness List – Page 2 of 14

Jeffrey Dihel

Baxter Healthcare 

Corporation

25212 W. Illinois Route 120, 

RLT2-W1

Round Lake, Illinois 60073

He will testify to the origin, manufacture, composition, and uses 

of the lactated ringer’s IV bags used at Baylor Scott & White 

Surgicare North Dallas in 2022 and Baxter’s review of the 

adverse incidents reported at Baylor Scott & White Surgicare 

North Dallas.

Brook Buchanan

12230 Coit Road, Suite 200

Dallas, Texas 75251

She will testify to her employment, duties, and experiences as a 

nurse at Baylor Scott & White Surgicare North Dallas, 

including her interactions with and observations of the 

defendant before, on, and after May 19, 2022 (the date of the 

surgery involving G.A.), as well as the surgery involving J.A.

on August 24, 2022.

Rumaldo Gonzalez

12230 Coit Road, Suite 200

Dallas, Texas 75251

He will testify to his employment, duties, and experiences as an 

employee at Baylor Scott & White Surgicare North Dallas, 

including his role with stocking IV bags in the warming bin, as 

well as his interactions with and observations of the defendant.

Hayley Torneden

12230 Coit Road, Suite 200

Dallas, Texas 75251

She will testify to her employment, duties, and experiences as a 

nurse at Baylor Scott & White Surgicare North Dallas, 

including her interactions with and observations of the 

defendant and his practices with IV bags.

Avery Dorris

12230 Coit Road, Suite 200

Dallas, Texas 75251

(also a records custodian)

She will testify to her employment, duties, and experiences as a 

nurse/administrator at Baylor Scott & White Surgicare North 

Dallas, including her knowledge of the adverse medical 

incidents from late May through August 2022 and her 

knowledge of the amount of transfers from the facility since its 

reopening after its closure in late August 2022. She will testify 

that the records detailed in the government’s 902(11) notice 

(doc. 104) were made at or near the time by — or from 

information transmitted by — someone with knowledge; the 

records were kept in the course of the regularly conducted 

activity of Baylor Scott and White Surgicare North Dallas, and 

that making the records was a regular practice of that activity.

Jordynn Feldmann She will testify to her employment and experiences as a 

certified registered nurse anesthetist with the defendant’s 

business (Garland Anesthesia Consultants) and at Baylor Scott 

& White Surgicare North Dallas, including her interactions with 

and observations of the defendant and his practices with IV 

bags before and after May 2022.

Ashley Burks

c/o attorney Nick Bunch

2801 North Harwood, Suite 

2300

She will testify to her employment, duties, and experiences as a 

nurse/administrator at Baylor Scott & White Surgicare North 

Dallas, including her knowledge of its procedures and practices, 

its scheduling of surgeries, its use of IV bags, and its video 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 2 of 14 PageID 1095
Government’s Witness List – Page 3 of 14

Dallas, Texas 75201 surveillance system and its recordings; her interactions with and 

observations of the defendant at Baylor Scott & White 

Surgicare North Dallas and as an employee/contractor for his 

businesses; the adverse incidents that occurred at Baylor Scott 

& White Surgicare North Dallas from late May through August 

2022 requiring hospital transfers; and her role in the facility’s 

investigation of those incidents.

Dr. William Carpenter, M.D.

12230 Coit Road, Suite 200

Dallas, Texas 75251

He will testify to his work as a surgeon at Baylor Scott & White 

Surgicare North Dallas, including his interactions with and 

observations of the defendant before, on, and after May 19, 

2022 and his involvement with the medical executive (peer 

review) committee addressing the defendant’s conduct 

concerning a patient (G.A.) at Baylor Scott & White Surgicare 

North Dallas on May 19, 2022. He will testify concerning the 

surgery involving M.N. on August 9, 2022 and the 

complications encountered and subsequent events.

Dr. Frederick Lester, M.D.

12230 Coit Road, Suite 200

Dallas, Texas 75251

He will testify to his work as a surgeon/medical director at 

Baylor Scott & White Surgicare North Dallas, including his 

interactions with and observations of the defendant before, on, 

and after May 19, 2022; his involvement with the medical 

executive (peer review) committee addressing the defendant’s 

conduct concerning a patient (G.A.) at Baylor Scott & White 

Surgicare North Dallas on May 19, 2022; and his role in the 

facility’s investigation of the adverse incidents occurring from 

late May through August 2022 and following J.A.’s surgery on 

August 24, 2022.

Dr. Imraan Sheikh, M.D.

7217 Telecom Parkway

Garland, Texas 75044

He will testify to his work as a gastroenterologist at Baylor 

Scott & White Surgicare North Garland, including his 

interactions with and observations of the defendant before, on, 

and after November 9, 2020 (the day of the surgery involving 

T.K. at Baylor Scott & White Surgicare North Garland in which 

the defendant was the anesthesiologist). 

Chris Palazola

Texas Medical Board 

P.O. Box 2018

Austin, Texas 78768-2018

He will testify to his role at the Texas Medical Board, his 

awareness of the Board’s disciplinary proceedings against the 

defendant, and the issuance of complaints and orders in those 

proceedings.

Terri Burson She will testify to her employment and experiences with the 

defendant and his businesses, including her roles at Garland 

Anesthesia Consultants, Assured Medical Billing, and other 

entities; her knowledge of those businesses and their sources of 

revenue and expenses; the employees of and contractors for 

those businesses; and the defendant’s use of revenue from those 

businesses.

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 3 of 14 PageID 1096
Government’s Witness List – Page 4 of 14

Nick Brown

U.S. Food & Drug 

Administration, Office of 

Criminal Investigations

8600 Freeport Pkwy., Suite 

340

Irving, Texas 75063

He will testify to his review and transcription of recordings 

involving the defendant made in October 2022. 

Dr. Elizabeth Kerner, M.D.

6130 Parker Road #110

Plano, Texas 75093

(also noticed as potential 

expert)

She will testify to her practice as a surgeon, including at Baylor 

Scott & White Surgicare North Dallas, and the surgeries 

involving T.Y. on August 4, 2022 and K.P. on August 18, 2022 

and August 19, 2022 and the complications encountered and 

subsequent events. She will offer her opinions about the 

surgeries as noted in the government’s expert disclosure (doc. 

52).

Dr. George Erdman, M.D.

6606 LBJ Freeway, Suite 200

Dallas, Texas 75240

(also noticed as potential 

expert)

He will testify to his practice as an anesthesiologist, including at 

Baylor Scott & White Surgicare North Dallas, and the surgery 

involving T.Y. on August 4, 2022 and the complications 

encountered and subsequent events. He will offer his opinions 

about the surgery as noted in the government’s expert disclosure 

(doc. 52).

Dr. Chad Marsden, M.D.

12222 Merit Drive, Suite 600

Dallas, Texas 75251

(also noticed as potential 

expert)

He will testify to his practice as an anesthesiologist, including at 

Baylor Scott & White Surgicare North Dallas, and the surgery 

involving K.P. on August 19, 2022 and the complications 

encountered and subsequent events. He will testify to his role 

in the investigation of the adverse medical events experienced at 

the facility from late May 2022 through August 2022, including 

that of J.A. on August 24, 2022. He will offer his opinions 

about the surgery and general anesthesia practice, including use 

and effects of drugs and other medications, as noted in the 

government’s expert disclosure (doc. 52).

Dr. Duc P. Vo, M.D.

2241 Peggy Lane, Suite A

Garland, Texas 75042

(also noticed as potential 

expert)

He will testify to his practice as a surgeon, including at Baylor 

Scott & White Surgicare North Dallas, and the surgery 

involving J.E. on August 9, 2022 and the complications 

encountered and subsequent events. He will testify to his 

involvement with the medical executive (peer review) 

committee addressing the defendant’s conduct concerning a 

patient (G.A.) at Baylor Scott & White Surgicare North Dallas 

on May 19, 2022. He will testify to his involvement with the 

medical executive (peer review) committee addressing the 

defendant’s conduct concerning a patient (T.K.) at Baylor Scott 

& White Surgicare North Garland on November 9, 2020. He 

will offer his opinions about the surgery as noted in the 

government’s expert disclosure (doc. 52). 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 4 of 14 PageID 1097
Government’s Witness List – Page 5 of 14

Dr. David Billman, M.D.

12222 Merit Drive, Suite 600

Dallas, Texas 75251

(also noticed as potential 

expert)

He will testify to his practice as an anesthesiologist, including at 

Baylor Scott & White Surgicare North Dallas, and the surgery 

involving J.E. on August 9, 2022, and the complications 

encountered and subsequent events. He will offer his opinions 

about the surgery as noted in the government’s expert disclosure 

(doc. 52)

Dr. Thomas Hung, M.D.

2700 Hillcrest Road, Suite 

900

Dallas, Texas 75230

(also noticed as potential 

expert)

He will testify to his practice as a surgeon, including at Baylor 

Scott & White Surgicare North Dallas and the surgery involving 

J.A. on August 24, 2022 and the complications encountered and 

subsequent events. He will offer his opinions about the surgery 

as noted in the government’s expert disclosure (doc. 52).

Dr. Saad Hussain, M.D.

12230 Coit Road, Suite 200

Dallas, Texas 75251

(also noticed as potential 

expert)

He will testify to his practice as an anesthesiologist, including at 

Baylor Scott & White Surgicare North Dallas and the surgery 

involving J.A. on August 24, 2022 and the complications 

encountered and subsequent events. He will offer his opinions 

about the surgery as noted in the government’s expert disclosure 

(doc. 52).

Kelly Carpenter

Madison Associates Inc.

U.S. Food & Drug 

Administration, Office of 

Criminal Investigations

8600 Freeport Pkwy., Suite 

340

Irving, Texas 75063

(also noticed as potential 

expert)

He will testify to his review of federal income tax returns and 

bank and credit card accounts records for the defendant and his 

businesses to discern income amounts, income sources, and 

expenditures, and offer his opinions of the defendant’s revenue 

and expenditures for certain periods. He will offer his opinions 

as noted in the government’s expert disclosure (doc. 42).

Manuela Esparza

Consumer Protection Branch

450 5th St. NW #6400

Washington, DC 20001

Ms. Esparza will testify about her review of certain portions of 

the surveillance videos recorded at Baylor Scott & White 

Surgicare North Dallas.

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 5 of 14 PageID 1098
Government’s Witness List – Page 6 of 14

Expert Witnesses

Dr. Stacey Hail, M.D. She will testify about the review she 

performed concerning the death of M.K. 

and the serious bodily injuries of T.Y., 

J.E., K.P., and J.A., in the context of 

multiple incidents of unexplained cardiac 

emergencies occurring from May 2022 

through August 2022 at Baylor Scott & 

White Surgicare North Dallas. She will 

testify whether there is a reasonable 

probability of serious adverse health 

consequences or death to an individual 

when that individual is administered 

adulterated intravenous fluids (IVF) that 

surreptitiously contain bupivacaine, 

lidocaine, epinephrine and/or ephedrine. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 43).

Dr. Guido Verbeck

Augusta University

1120 15th Street GE1027

Augusta, Georgia 30912

He will describe physical and chemical 

testing of IV bags and offer his opinions 

as noted in the government’s expert 

disclosure (doc. 41).

Ashley Smith Juel

University of North Texas

1155 Union Circle #305070

Denton, Texas 76203

She will describe physical and chemical 

testing of IV bags and offer her opinions 

as noted in the government’s expert 

disclosure (doc. 41).

Dr. Elizabeth Ventura, M.D.

Dallas County Medical Examiner’s Office

2355 N Stemmons Freeway

Dallas, Texas 75207

She will testify to her role and experience 

as a Medical Examiner, including the 

autopsy she performed on M.K. on June 

22, 2022, and that based on that 

examination, her review of M.K.’s 

toxicology tests, her review of subsequent 

events that occurred at the Baylor Scott & 

White North Dallas Surgicare facility in 

2022, and her review of scientific testing 

related to the subsequent events, that M.K. 

“died as a result of the toxic effects of 

bupivacaine.” She will offer her opinions 

as noted in the government’s expert 

disclosure (doc. 50).

Brittany Welch

SWIFS

She will testify to her role and work as a 

Toxicology Chemist III at SWIFS, 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 6 of 14 PageID 1099
Government’s Witness List – Page 7 of 14

2355 N Stemmons Freeway 

Dallas, Texas 75207

including her review of the testing 

performed concerning the blood samples 

of M.K., K.P., and J.A. and the 

conclusions she reached about those tests. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 49).

Dr. Kari Midthun

NMS Labs

200 Welsh Road

Horsham, Pennsylvania 19044

She will testify to her role and work as a 

Forensic Toxicologist at NMS Labs, 

including her review of the testing 

performed concerning the blood samples 

of M.K., K.P., and J.A. and the 

conclusions she reached about those tests 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 51).

Possible Witnesses

Chad Medaris

U.S. Food & Drug Administration, Office 

of Criminal Investigations

8600 Freeport Pkwy., Suite 340

Irving, Texas 75063

He will testify to the criminal 

investigation of the defendant, including 

the collection of evidence and interviews 

of witnesses.

Daniel Allgeyer

U.S. Food & Drug Administration, Office 

of Criminal Investigations

8600 Freeport Pkwy., Suite 340

Irving, Texas 75063

He will testify to the criminal 

investigation of the defendant, including 

the collection of evidence and interviews 

of witnesses.

Andrea Watson

Dallas Police Department

1400 Botham Jean Blvd.

Dallas, Texas 75215

She will testify to the criminal 

investigation of the defendant, including 

the collection of evidence and interviews 

of witnesses.

David Grubbs

Dallas Police Department

1400 Botham Jean Blvd.

Dallas, Texas 75215

He will testify to the criminal 

investigation of the defendant, including 

the collection of evidence and interviews 

of witnesses.

Michael Freeman

Dallas Police Department

1400 Botham Jean Blvd.

Dallas, Texas 75215

He will testify to copying the DVR used 

for video surveillance at Baylor Scott & 

White Surgicare North Dallas.

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 7 of 14 PageID 1100
Government’s Witness List – Page 8 of 14

D. Hulbert

Dallas Police Department

1400 Botham Jean Blvd.

Dallas, Texas 75215

He will testify to retrieving evidence for 

the Dallas Police Department from the 

Southwestern Institute of Forensic Science 

in case nos. IFS-22-12341, 22-IFS-17256, 

and IFS-22-17336. 

Rachel McGehee

SWIFS

2355 N Stemmons Freeway Dallas, Texas

75207

She will testify to her role as an Evidence 

Registrar in case no. 22-IFS-12341 

(related to victim M.K.) at the 

Southwestern Institute of Forensic 

Science, including sealing blood evidence 

and transporting it within the 

Southwestern Institute of Forensic 

Science.

Monica Chavez 

SWIFS

2355 N Stemmons Freeway Dallas, Texas

75207

She will testify to her role as an Evidence 

Registrar in case nos. 22-IFS-17256 

(related to victim J.A.) and 22-IFS-17336 

(related to victim K.P.) at the 

Southwestern Institute of Forensic 

Science, including both receiving and 

logging blood evidence in and releasing it 

to the Dallas Police Department. 

Abel Martin

SWIFS

2355 N Stemmons Freeway Dallas, Texas

75207

He will testify to his role as an Evidence 

Registrar in case nos. 22-IFS-12341 

(related to victim M.K.), 22-IFS-17256 

(related to victim J.A.), and 22-IFS-17336 

(related to victim K.P.) at the 

Southwestern Institute of Forensic 

Science, including sealing blood evidence 

and transporting it within the 

Southwestern Institute of Forensic 

Science.

Floyd Martin

SWIFS

2355 N Stemmons Freeway Dallas, Texas

75207

He will testify to his role as an Evidence 

Registrar in case no. 22-IFS-12341 

(related to victim M.K.) at the 

Southwestern Institute of Forensic 

Science, including disposing of blood 

evidence.

Megan Savage

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

She will testify to her role and work as a 

Toxicology Chemist II at SWIFS, 

including her involvement in the testing of 

M.K.’s blood sample for bupivacaine. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 49).

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 8 of 14 PageID 1101
Government’s Witness List – Page 9 of 14

Darya Vassilieva

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

She will testify to her role and work as a 

Forensic Toxicologist II at SWIFS, 

including her involvement in the testing of 

M.K.’s blood sample for bupivacaine. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 49).

Liza Chacko

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

She will testify to her role and work as a 

Toxicology Chemist II at SWIFS, 

including her involvement in the testing of 

K.P.’s and J.A.’s blood samples for 

ephedrine, lidocaine, and bupivacaine. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 49).

Heidi Christensen

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

She will testify to her role and work as a 

Toxicology Chemist II at SWIFS, 

including her involvement in the testing of 

K.P.’s and J.A.’s blood samples for 

ephedrine, lidocaine, and bupivacaine. 

She will offer her opinions as noted in the 

government’s expert disclosure (doc. 49).

Amanda Rausch

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

She will testify to her role and work as a 

Toxicology Chemist II at SWIFS, 

including her involvement in the 

preparation of a sample of M.K.’s blood 

for shipment to NMS Labs or subsequent 

testing. She will offer her opinions as 

noted in the government’s expert 

disclosure (doc. 49).

David Baxter

SWIFS

2355 N Stemmons Freeway

Dallas, Texas 75207

(also noticed as potential expert)

He will testify to his role and work as a 

Toxicologist II at SWIFS, including his 

involvement in the preparation of samples 

of K.P.’s and J.A.’s blood for shipment to 

NMS Labs for subsequent testing. He will 

offer his opinions as noted in the 

government’s expert disclosure (doc. 49).

Rachel Barrett

NMS

200 Welsh Road

Horsham, Pennsylvania 19044

(also noticed as potential expert)

She will testify to her role and work as an 

Analyst II at NMS Labs, including her 

involvement in the testing of J.A.’s and 

K.P.’s blood samples for ephedrine. She 

will offer her opinions as noted in the 

government’s expert disclosure (doc. 51).

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 9 of 14 PageID 1102
Government’s Witness List – Page 10 of 14

Danica Martin

NMS

200 Welsh Road

Horsham, Pennsylvania 19044

(also noticed as potential expert)

She will testify to her role and work as an 

Analyst II at NMS Labs, including her 

involvement in the testing of J.A.’s and 

K.P.’s blood samples for ephedrine.as

noted in the government’s expert 

disclosure (doc. 51).

Alexis McCrossan

NMS

200 Welsh Road

Horsham, Pennsylvania 19044

(also noticed as potential expert)

She will testify to her role and work as an 

Analyst II at NMS Labs, including her 

involvement in the testing of M.K.’s blood 

sample for bupivacaine. She will offer her 

opinions as noted in the government’s 

expert disclosure (doc. 51).

Mark Shadle

NMS

200 Welsh Road

Horsham, Pennsylvania 19044

(also noticed as potential expert)

He will testify to his role and work as an 

Analyst II at NMS Labs, including his

involvement in the testing of K.P.’s blood 

sample for bupivacaine. He will offer his

opinions as noted in the government’s 

expert disclosure (doc. 51).

Jacclyn J. McGuinness, CPA

241 N. Murphy Road

Murphy, Texas 75094

She will testify to being the defendant’s 

CPA and handling the federal tax filings 

for him and the corporations he controlled, 

including her knowledge of their financial 

records documenting income, expenses, 

payroll, corporate structure, distributions, 

and other financial and business aspects. 

Dr. Mark Miller, M.D.

3144 Horizon Road, Ste. 210

Rockwall, Texas 75032

He will testify to his work as a 

gastroenterologist at Baylor Scott & White 

Surgicare North Garland, including his 

involvement with the surgical procedures 

on November 18, 2020 (patient I.R.)and 

on December 16, 2020 (patient R.D.)in 

which complications arose before surgery 

in the pre-operative area of the facility. 

Tammy Beck

FDA

8600 Freeport Parkway #340

Irving, Texas 75063

She will testify to her oversight and 

custody of the evidence collected in the 

investigation of the defendant. 

Emily Smith

Baylor Scott & White Rockwall

She will testify to her knowledge of the 

adverse medical incident involving patient

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 10 of 14 PageID 1103
Government’s Witness List – Page 11 of 14

825 West Yellowjacket Lane

Rockwall, Texas 75087

(T.K.) at Baylor Scott & White Surgicare 

North Garland on November 9, 2020 in 

which the defendant was the 

anesthesiologist, and the adverse medical 

incidents on November 18, 2020 (patient 

I.R.) and on December 16, 2020 (R.D.) in 

which complications arose before surgery 

in the pre-operative area of the facility. 

Frankie Joe Marical He will testify to the installation and 

operation of the DVR (video recording) 

surveillance system at Baylor Scott & 

White Surgicare North Dallas in May 

2022. 

Records Custodians

Tykeisha Washington

Kaye Sutton

Kavya Shekar

Tammy Tatum

(or designee)

JPMorgan Chase Bank N.A.

383 Madison Avenue

New York, New York 10017

Will testify that the five batches of 

JPMorgan Chase Bank, NA. financial 

records detailed in the government’s 

902(11) notice (doc. 40) were made at or 

near the time by — or from information 

transmitted by — someone with 

knowledge; the records were kept in the 

course of the regularly conducted activity 

of JPMorgan Chase Bank, NA.; and that 

making the records was a regular practice 

of that activity. 

Alexis Wilks (or designee)

Bank of America, NA

100 North Tryon Street

Charlotte, North Carolina 28255

Will testify that the two batches of Bank 

of America, NA

financial records detailed in the 

government’s 902(11) notice (doc. 40)

were made at or near the time by — or 

from information transmitted by —

someone with knowledge; the records 

were kept in the course of the regularly 

conducted activity of Bank of America, 

NA; and that making the records was a 

regular practice of that activity. 

Donna Lund (or designee)

American Express 

200 Vesey Street

New York, New York 10285

Will testify that the two batches of 

American Express financial records 

detailed in the government’s 902(11) 

notice (doc. 40) were made at or near the 

time by — or from information 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 11 of 14 PageID 1104
Government’s Witness List – Page 12 of 14

transmitted by — someone with 

knowledge; the records were kept in the 

course of the regularly conducted activity 

of Bank of America, NA; and that making 

the records was a regular practice of that 

activity.

Cory Ibanez

Correct Solutions LLC

182 Bastille Lane

Ruston, Louisiana 71270

Will testify that the three items detailed in 

the government’s 902(11) notice (doc. 80)

were made at or near the time by — or 

from information transmitted by —

someone with knowledge; the records 

were kept in the course of the regularly 

conducted activity of Correct Solutions 

LLC; and that making the records was a 

regular practice of that activity.

Melissa Monmouth (or designee)

Medical City

7777 Forest Lane

Dallas, Texas 75230

Will testify that the four batches of 

Medical City records detailed in the 

government’s 902(11) notice (doc. 40) 

were made at or near the time by — or 

from information transmitted by —

someone with knowledge; the records 

were kept in the course of the regularly 

conducted activity of Medical City; and 

that making the records was a regular 

practice of that activity.

Erin Farmer (or designee)

Texas Health Resources

612 East Lamar Blvd.

Arlington, Texas 76011

Will testify that the batch of Texas Health 

Resources records detailed in the 

government’s 902(11) notice (doc. 104) 

were made at or near the time by — or 

from information transmitted by —

someone with knowledge; the records 

were kept in the course of the regularly 

conducted activity of Texas Health 

Resources; and that making the records 

was a regular practice of that activity.

Morgan Meaders (or designee)

Baylor Scott and White Surgicare North 

Garland

7150 N. President George Bush Hwy #101 

Garland, Texas 75044

Will testify that the batch of Baylor Scott 

and White Surgicare North Garland

records detailed in the government’s 

902(11) notice (doc. 104) were made at or 

near the time by — or from information 

transmitted by — someone with 

knowledge; the records were kept in the 

course of the regularly conducted activity 

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 12 of 14 PageID 1105
Government’s Witness List – Page 13 of 14

of Baylor Scott and White Surgicare 

North Garland; and that making the 

records was a regular practice of that 

activity.

Respectfully submitted,

LEIGHA SIMONTON

UNITED STATES ATTORNEY

/s/ John J. de la Garza III

JOHN J. DE LA GARZA III

Assistant United States Attorney

Texas Bar No. 00796455

1100 Commerce Street, Third Floor

Dallas, Texas 75242-1699

Tel: (214) 659.8682

Fax: (214) 659.8812

Email: john.delagarza@usdoj.gov

PATRICK R. RUNKLE

Senior Litigation Counsel

RACHEL BARON

Trial Attorney

Consumer Protection Branch

U.S. Department of Justice

P.O. Box 386

Washington, DC 20044-0386

Tel: 202.532.4723

Email: ratrick.runkle@usdoj.gov

Email: rachel.baron@usdoj.gov

Certificate of Service

I certify that on March 22, 2024 I electronically filed this document with the Clerk 

for the United States District Court for the Northern District of Texas pursuant to its 

electronic filing system (ECF). The ECF sent a “Notice of Electronic Filing” to the 

attorneys of record who have consented to accepting service via this method. 

/s/ John J. de la Garza III

JOHN J. DE LA GARZA III

Assistant United States Attorney

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 13 of 14 PageID 1106
Government’s Witness List – Page 14 of 14

Case 3:22-cr-00378-N Document 121 Filed 03/22/24 Page 14 of 14 PageID 1107