That I, , as a representative and guardian of , have made, constituted, and appointed, and do so by this instrument hereby make, constitute, empower, and appoint, Paige Boldt, Mikal C. Watts, and or WATTS GUERRA, Attorneys at Law (collectively, my “attorneys”), 5726 W Hausman Rd, Suite 119, San Antonio, Texas 78249, as my true and lawful attorneys for me and give my attorneys the powers listed below to act in my name, place, and stead to appear for and represent me in the claims involving the February 3, 2023 Norfolk Southern East Palestine, OH Train Derailment giving my said attorneys full power to do everything whatsoever requisite and necessary and in any way which I, myself, could do if I were personally present.
My attorneys’ powers shall include the power to: (a) take any and all steps necessary to request and collect medical and pharmacy records related to my representation; (b) take any and all steps necessary to request and collect any and all mental health records related to my representation; (c) take any and all actions necessary to resolve issues with ordering medical and or pharmaceutical records, including signing my name to medical, pharmacy, Health Insurance Portability and Accountability Act of 1996 (HIPAA), and similar authorizations, or otherwise digitally affixing a copy of my signature to said authorizations, in order to obtain medical and pharmaceutical records related to my representation; (d) take any and all actions necessary to verify, affirm, and or attest to discovery responses in my lawsuit, including plaintiff fact sheets or similar requests, including signing my name to said discovery documents, or otherwise digitally affixing a copy of my signature to said documents; and (e) take any and all actions necessary to identify and resolve liens that are or might be asserted related to my injuries, including, but not limited to Medicare, Medicaid, insurance, workers compensation, and or other health care related liens, by signing my name or otherwise digitally affixing a copy of my signature to documents retaining, and otherwise utilizing, specialized lien resolution groups to assist in said matters.
It is understood and agreed that the attorneys’ fees in my case are governed by and are subject to the attorney Employment Contract entered into between WATTS GUERRA and myself, and further, no settlement will be made without my consent. This Power of Attorney shall become effective immediately upon execution; however, I may revoke this power of attorney at any time by providing written notice to my Attorneys.
I agree that any third party who receives a copy of this document may act under it. Revocation of this power of attorney is not effective as to a third party until the third party receives actual notice of the revocation. I agree to indemnify the third party for any claims that arise against the third party because of reliance on this power of attorney.
IN TESTIMONY WHEREOF, I have hereunto set my signature, this