On March 19, 2021 a
Answer
was filed
involving a dispute between
Kay Medical Center, Pllc,
Khit & Associates, L.L.C. D B A Khit Chiropractic & Wellness Centers,
Skak Investments, L.L.C. D B A Insight Diagnostics & Imaging Centers,
and
Law Offices Of Ezequiel Reyna, Jr. P.C.,
Reyna, Ezequiel, Jr.,
Ruiz, Gustavo C,
Ruiz Law Center, Pllc,
for Contract - Other Contract (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
7/22/2022 1:41 PM
Hidalgo County District Clerks
Reviewed By: Irma Lopez
CAUSE NO. C-1080-21-J
KHIT & ASSOCIATES, L.L.C. D/B/A KHIT § IN THE DISTRICT COURT
CHIROPRACTIC & WELLNESS CENTER §
And SKAK INVESTMENTS, L.L.C. D/B/A §
INSIGHT DIAGNOSTICS & IMAGING §
CENTERS, §
Plaintiffs §
§
VS. § 430TH JUDICIAL DISTRICT
§
LAW OFFICES OF EZEQUIEL REYNA, JR. §
P.C., EZEQUIEL REYNA, JR., RUIZ LAW §
CENTER, PLLC and GUSTAVO C. RUIZ, §
Defendants § HIDALGO COUNTY, TEXAS
DEFENDANTS RUIZ LAW CENTER, PLLC and GUSTAVO C. RUIZ’S
SUPPLEMENTAL ANSWER
COME NOW RUIZ LAW CENTER, P.L.L.C. and GUSTAVO C. RUIZ (Defendants) filing this,
their Supplemental Answer to Plaintiffs’ pleadings, showing the Court the following:
As a supplement to these Defendants’ prior pleadings, and still in all things relying upon those
prior pleadings, this Supplemental Answer and the affirmative defenses set forth herein is respectfully
submitted.
I.
CLAIMS BARRED BY LIMITATION
Plaintiffs’ claims are barred by the applicable statute of limitation.
II.
CLAIMS BARRED BY LACHES
Plaintiffs’ claims are barred by the doctrine of laches.
III.
ACCORD AND SATISFACTION
Defendants affirmatively plead accord and satisfaction as to Plaintiffs’ claims.
IV.
PRAYER
[ln] R\R-\Defs’ Original Ans Page 1 of 2
Electronically Filed
7/22/2022 1:41 PM
Hidalgo County District Clerks
Reviewed By: Irma Lopez
WHEREFORE, PREMISES CONSIDERED, Defendants pray that, upon final hearing, Plaintiffs
recover nothing. Defendants also pray for relief as authorized by law and/or equity, including judgment
in their favor and such other and further relief that Defendants may show themselves justly entitled to
receive, including but not limited to, a recovery of all court costs and sanctions.
Respectfully submitted,
ADAMS & GRAHAM, L.L.P.
134 E. Van Buren, Suite 301 (78550)
Post Office Drawer 1429
Harlingen, Texas 78551-1429
Phone: (956) 428-7495 - Ext. 145
Facsimile: (956) 428-2954
By: William L. Pope
WILLIAM L. POPE
State Bar No. 16139020
Federal ID No. (S.D. – Texas) 8970
U.S. Tax Court ID No. PW0378
Email: pope@adamsgraham.com
Attorneys for Ruiz Law Center, PLLC and
Gustavo C. Ruiz
CERTIFICATE OF SERVICE
I hereby certify that on the 22nd day of July, 2022, a true and correct copy of the above and
foregoing Supplemental Answer of Ruiz Law Center, PLLC and Gustavo C. Ruiz, was served upon to
the following counsel of record, via electronic service, to wit:
Lance Christopher Kassab Via E-Filing: eserve@kassablaw.com
THE KASSAB LAW FIRM Via E-Filing: lance@kassablaw.com
1215 Elgin Street
Houston, Texas 77004
Micah Dortch Via E-filing: mdortch@potts-law.com
The Potts Law Firm, P.C.
2911 Turtle Creek Blvd., Suite 1000
Dallas, Texas 75219
William L. Pope
WILLIAM L. POPE
[ln] R\R-\Defs’ Original Ans Page 2 of 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.
William Pope on behalf of William Pope
Bar No. 16139020
pope@adamsgraham.com
Envelope ID: 66587410
Status as of 7/22/2022 1:51 PM CST
Associated Case Party: Khit & Associates, L.L.C. d/b/a Khit Chiropractic & Wellness Centers
Name BarNumber Email TimestampSubmitted Status
Lance Kassab eserve@kassab.law 7/22/2022 1:41:32 PM SENT
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.
William Pope on behalf of William Pope
Bar No. 16139020
pope@adamsgraham.com
Envelope ID: 66587410
Status as of 7/22/2022 1:51 PM CST
Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C.
Name BarNumber Email TimestampSubmitted Status
Timothy MicahDortch mdortch@potts-law.com 7/22/2022 1:41:32 PM SENT
Maryssa JSimpson msimpson@potts-law.com 7/22/2022 1:41:32 PM SENT
Luisa Ulluela lulluela@potts-law.com 7/22/2022 1:41:32 PM SENT
Lance Livingston llivingston@potts-law.com 7/22/2022 1:41:32 PM SENT
MICAH DORTCH MDORTCH@POTTS-LAW.COM 7/22/2022 1:41:32 PM SENT
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.
William Pope on behalf of William Pope
Bar No. 16139020
pope@adamsgraham.com
Envelope ID: 66587410
Status as of 7/22/2022 1:51 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 7/22/2022 1:41:32 PM SENT
William Pope pope@adamsgraham.com 7/22/2022 1:41:32 PM SENT
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.
William Pope on behalf of William Pope
Bar No. 16139020
pope@adamsgraham.com
Envelope ID: 66587410
Status as of 7/22/2022 1:51 PM CST
Associated Case Party: Ruiz Law Center, PLLC
Name BarNumber Email TimestampSubmitted Status
William L.Pope pope@adamsgraham.com 7/22/2022 1:41:32 PM SENT
Nanci Gracia nancigracia@adamsgraham.com 7/22/2022 1:41:32 PM SENT
Document Filed Date
July 22, 2022
Case Filing Date
March 19, 2021
Category
Contract - Other Contract (OCA)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically Filed 7/22/2022 1:41 PM Hidalgo County District Clerks Reviewed By: Irma Lopez CAUSE NO. C-1080-21-J KHIT & ASSOCIATES, L.L.C. D/B/A KHIT § IN THE DISTRICT COURT CHIROPRACTIC & WELLNESS CENTER § And SKAK INVESTMENTS, L.L.C. D/B/A § INSIGHT DIAGNOSTICS & IMAGING § CENTERS, § Plaintiffs § § VS. § 430TH JUDICIAL DISTRICT § LAW OFFICES OF EZEQUIEL REYNA, JR. § P.C., EZEQUIEL REYNA, JR., RUIZ LAW § CENTER, PLLC and GUSTAVO C. RUIZ, § Defendants § HIDALGO COUNTY, TEXAS DEFENDANTS RUIZ LAW CENTER, PLLC and GUSTAVO C. RUIZ’S SUPPLEMENTAL ANSWER COME NOW RUIZ LAW CENTER, P.L.L.C. and GUSTAVO C. RUIZ (Defendants) filing this, their Supplemental Answer to Plaintiffs’ pleadings, showing the Court the following: As a supplement to these Defendants’ prior pleadings, and still in all things relying upon those prior pleadings, this Supplemental Answer and the affirmative defenses set forth herein is respectfully submitted. I. CLAIMS BARRED BY LIMITATION Plaintiffs’ claims are barred by the applicable statute of limitation. II. CLAIMS BARRED BY LACHES Plaintiffs’ claims are barred by the doctrine of laches. III. ACCORD AND SATISFACTION Defendants affirmatively plead accord and satisfaction as to Plaintiffs’ claims. IV. PRAYER [ln] R\R-\Defs’ Original Ans Page 1 of 2 Electronically Filed 7/22/2022 1:41 PM Hidalgo County District Clerks Reviewed By: Irma Lopez WHEREFORE, PREMISES CONSIDERED, Defendants pray that, upon final hearing, Plaintiffs recover nothing. Defendants also pray for relief as authorized by law and/or equity, including judgment in their favor and such other and further relief that Defendants may show themselves justly entitled to receive, including but not limited to, a recovery of all court costs and sanctions. Respectfully submitted, ADAMS & GRAHAM, L.L.P. 134 E. Van Buren, Suite 301 (78550) Post Office Drawer 1429 Harlingen, Texas 78551-1429 Phone: (956) 428-7495 - Ext. 145 Facsimile: (956) 428-2954 By: William L. Pope WILLIAM L. POPE State Bar No. 16139020 Federal ID No. (S.D. – Texas) 8970 U.S. Tax Court ID No. PW0378 Email: pope@adamsgraham.com Attorneys for Ruiz Law Center, PLLC and Gustavo C. Ruiz CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of July, 2022, a true and correct copy of the above and foregoing Supplemental Answer of Ruiz Law Center, PLLC and Gustavo C. Ruiz, was served upon to the following counsel of record, via electronic service, to wit: Lance Christopher Kassab Via E-Filing: eserve@kassablaw.com THE KASSAB LAW FIRM Via E-Filing: lance@kassablaw.com 1215 Elgin Street Houston, Texas 77004 Micah Dortch Via E-filing: mdortch@potts-law.com The Potts Law Firm, P.C. 2911 Turtle Creek Blvd., Suite 1000 Dallas, Texas 75219 William L. Pope WILLIAM L. POPE [ln] R\R-\Defs’ Original Ans Page 2 of 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. William Pope on behalf of William Pope Bar No. 16139020 pope@adamsgraham.com Envelope ID: 66587410 Status as of 7/22/2022 1:51 PM CST Associated Case Party: Khit & Associates, L.L.C. d/b/a Khit Chiropractic & Wellness Centers Name BarNumber Email TimestampSubmitted Status Lance Kassab eserve@kassab.law 7/22/2022 1:41:32 PM SENT 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. William Pope on behalf of William Pope Bar No. 16139020 pope@adamsgraham.com Envelope ID: 66587410 Status as of 7/22/2022 1:51 PM CST Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C. Name BarNumber Email TimestampSubmitted Status Timothy MicahDortch mdortch@potts-law.com 7/22/2022 1:41:32 PM SENT Maryssa JSimpson msimpson@potts-law.com 7/22/2022 1:41:32 PM SENT Luisa Ulluela lulluela@potts-law.com 7/22/2022 1:41:32 PM SENT Lance Livingston llivingston@potts-law.com 7/22/2022 1:41:32 PM SENT MICAH DORTCH MDORTCH@POTTS-LAW.COM 7/22/2022 1:41:32 PM SENT 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. William Pope on behalf of William Pope Bar No. 16139020 pope@adamsgraham.com Envelope ID: 66587410 Status as of 7/22/2022 1:51 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 7/22/2022 1:41:32 PM SENT William Pope pope@adamsgraham.com 7/22/2022 1:41:32 PM SENT 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. William Pope on behalf of William Pope Bar No. 16139020 pope@adamsgraham.com Envelope ID: 66587410 Status as of 7/22/2022 1:51 PM CST Associated Case Party: Ruiz Law Center, PLLC Name BarNumber Email TimestampSubmitted Status William L.Pope pope@adamsgraham.com 7/22/2022 1:41:32 PM SENT Nanci Gracia nancigracia@adamsgraham.com 7/22/2022 1:41:32 PM SENT