State of Texas v. Xerox Corporation Settlement Proceeds

Opinion

ACCEPTED 15-25-00034-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/15/2025 10:00 AM CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 5/15/2025 10:00:42 AM CHRISTOPHER A. PRINE Clerk BRIAN VANDERZANDEN PHONE: (512) 936-9929 Assistant Attorney General FAX: (512) 499-0712 Healthcare Program Enforcement EMAIL: Brian.VanderZanden@oag.texas.gov

May 15, 2025

VIA ECF FILING

Christopher A. Prine, Clerk Fifteenth Court of Appeals 300 W. 15th Street, Suite 607 Austin, Texas 78701

RE: Court of Appeals Number: 15-25-00034-CV Trial Court Case Number: D-1-GN-19-004849

Style: State of Texas v. Xerox Corporation, et al. Settlement Proceeds

Dear Mr. Prine,

The State submits this letter in response to the Court’s April 30, 2025, letter requesting confirmation that arrangements have been made to pay for the clerk’s record.

The State initially submitted payment for the clerk’s record on March 25, 2025. The State was later informed that the invoice it had received was for the incorrect amount. A new invoice was provided to the State by the district clerk on May 1, 2025. The State submitted the corrected payment amount on May 9, 2025 (see attached). Later that day the 15th Court of Appeals received an incomplete portion of the clerk’s record that excluded certain video exhibits.

The State was informed that the district clerk cannot release certain video exhibits without an order from the trial court directing it to do so. The State submitted an agreed-upon proposed order to the trial court on May 13, 2025, that directs the district clerk to send the video exhibits over to the 15th Court of Appeals. The State anticipates that the trial court will sign the proposed order shortly, which will allow for the release of certain video exhibits. Sincerely,

Brian VanderZanden BRIAN VANDERZANDEN Assistant Attorney General Healthcare Program Enforcement Division

cc: Charles S. Siegel Caitlyn E. Silhan Waters & Kraus, LLP Email: csiegel@waterskraus.com Email: csilhan@waterskraus.com

James R. Moriarty Law Offices of James R. Moriarty Email: jim@moriarty.com

James “Rusty” Tucker” Law Offices of James R. Tucker, P.C. Email: rusty@rustytuckerlaw.com

2 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Lynette Karch-Schroder on behalf of Brian VanderZanden Bar No. 24081557 Lynette.karch-schroder@oag.texas.gov Envelope ID: 100866677 Filing Code Description: Letter Filing Description: 20250515 SOT Ltr to 15COA re Clerks Record Status as of 5/15/2025 10:52 AM CST

Associated Case Party: Christine Ellis

Name BarNumber Email TimestampSubmitted Status

Caitlyn Silhan 24072879 csilhan@waterskraus.com 5/15/2025 10:00:42 AM SENT

James Moriarty 14459000 jim@moriarty.com 5/15/2025 10:00:42 AM SENT

Charles S.Siegel csiegel@waterskraus.com 5/15/2025 10:00:42 AM SENT

Associated Case Party: Alexandra Alvarez

Name BarNumber Email TimestampSubmitted Status

James Tucker 20272020 rusty@rustytuckerlaw.com 5/15/2025 10:00:42 AM SENT

Associated Case Party: Joshua LaFountain

Name BarNumber Email TimestampSubmitted Status

James Tucker 20272020 rusty@rustytuckerlaw.com 5/15/2025 10:00:42 AM SENT

Associated Case Party: State of Texas

Name BarNumber Email TimestampSubmitted Status

Brian Vanderzanden brian.vanderzanden@oag.texas.gov 5/15/2025 10:00:42 AM SENT

Lynette Karch-Schroder lynette.karch-schroder@oag.texas.gov 5/15/2025 10:00:42 AM SENT

Brittany Peters Brittany.Peters@oag.texas.gov 5/15/2025 10:00:42 AM SENT