In Re Nonparty Patient No. 1, Nonparty Patient No. 2, Nonparty Patient No. 3, Nonparty Patient No. 4, Nonparty Patient No. 5, Nonparty Patient No. 6, Nonparty Patient No. 7, Nonparty Patient No. 8, Nonparty Patient No. 9, Nonparty Patient No. 10, and Nonparty Patient No. 11 v. the State of Texas
This text of In Re Nonparty Patient No. 1, Nonparty Patient No. 2, Nonparty Patient No. 3, Nonparty Patient No. 4, Nonparty Patient No. 5, Nonparty Patient No. 6, Nonparty Patient No. 7, Nonparty Patient No. 8, Nonparty Patient No. 9, Nonparty Patient No. 10, and Nonparty Patient No. 11 v. the State of Texas (In Re Nonparty Patient No. 1, Nonparty Patient No. 2, Nonparty Patient No. 3, Nonparty Patient No. 4, Nonparty Patient No. 5, Nonparty Patient No. 6, Nonparty Patient No. 7, Nonparty Patient No. 8, Nonparty Patient No. 9, Nonparty Patient No. 10, and Nonparty Patient No. 11 v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
ACCEPTED 15-25-00031-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/21/2025 12:39 AM NO. _______________________ CHRISTOPHER A. PRINE CLERK IN THE FIFTEENTH DISTRICT COURT OF APPEALS FOR THE STATE OF FILED TEXAS IN AT AUSTIN, TEXAS 15th COURT OF APPEALS AUSTIN, TEXAS 3/21/2025 12:39:30 AM Nonparty Patient No. 1, Nonparty Patient No. 2, Nonparty Patient No.A.3,PRINE CHRISTOPHER Nonparty Patient No. 4, Nonparty Patient No. 5, Nonparty Patient No. 6, Clerk Nonparty Patient No. 7, Nonparty Patient No. 8, Nonparty Patient No. 9, Nonparty Patient No. 10, and Nonparty Patient No. 11, Relators
On Petition for Writ of Mandamus From the 493rd District Court at Collin County, Texas, Cause No. 4 93-08026-2024 The Honorable Judge Christine A. Nowak, Presiding
DECLARATION OF WILLIAM M. LOGAN IN SUPPORT OF PETITION FOR WRIT OF MANDAMUS
Jervonne D. Newsome (Lead Counsel) William M. Logan Texas Bar No. 24094869 Texas Bar No. 24106214 jnewsome@winston.com wlogan@winston.com Thanh D. Nguyen Evan D. Lewis Texas Bar No. 24126931 Texas Bar No. 24116670 tdnguyen@winston.com edlewis@winston.com WINSTON & STRAWN LLP Olivia A. Wogon 2121 N. Pearl St., 9th Floor Texas Bar No. 24137299 Dallas, TX 75201 oawogon@winston.com Telephone: (214) 453-6500 WINSTON & STRAWN LLP 800 Capitol Street, Suite 2400 Houston, TX 77002 Telephone: (713) 651-2600 1. My name is William M. Logan. I represent Relators in this Petition for
Writ of Mandamus. I am a member in good standing of the State Bar of Texas. I
provide this Declaration in support of Relators’ Petition for Writ of Mandamus. I
have personal knowledge of the facts stated herein, and I could and would testify
thereto if called as a witness in this matter.
2. On March 20, 2025, Respondent held a hearing in the 493rd District
Court regarding several issues pending before it in the underlying litigation.
3. Of relevance to this Petition, Respondent ruled that Children’s must
produce the unrepresented patients’ medical records to the counsel for the doctors
beginning March 21, with rolling productions to continue thereafter. This must
occur even though the Hospital Systems suggested certain records commingled the
unrepresented patients’ records with Relators’.
4. Respondent further ruled that Children’s must produce Relators’
medical records to the counsel for Relators (not the State) beginning March 21. On
April 16, the Collin County court will conduct an in camera review of decide
whether undersigned counsel shall turn over Relators’ medical records to the State.
5. Finally, Respondent ruled that UT Southwestern will produce no
records because of a pending issue regarding which attorney will represent UT
Southwestern. However, once that is resolved, UT Southwestern will proceed on the same track as Children’s when it comes to the unrepresented patients’ records
and Relators’ records.
6. At the hearing, counsel for Relators orally moved Respondent to
reconsider its rulings, particularly in light of the fact that Relators have serious
concerns that production of the unrepresented patients’ documents seriously
jeopardizes the privileges asserted by Relators. This is because the represented
patients’ documents are very likely comingled with the unrepresented patients’
documents. This matter is also pending before the Dallas Court.
7. The Court denied this motion.
I declare under penalty of perjury that the foregoing is true and correct.
Executed in Dallas County, State of Texas, on the 20th day of March, 2025.
/s/ William M. Logan
William M. Logan
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In Re Nonparty Patient No. 1, Nonparty Patient No. 2, Nonparty Patient No. 3, Nonparty Patient No. 4, Nonparty Patient No. 5, Nonparty Patient No. 6, Nonparty Patient No. 7, Nonparty Patient No. 8, Nonparty Patient No. 9, Nonparty Patient No. 10, and Nonparty Patient No. 11 v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-nonparty-patient-no-1-nonparty-patient-no-2-nonparty-patient-no-texapp-2025.