On March 19, 2021 a
Motion,Ex Parte
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
8/1/2022 4:01 PM
Hidalgo County District Clerks
Reviewed By: Edgar Sandoval
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, PLCC and
GUSTAVO C. RUIZ’ MOTION TO QUASH
TO THE HONORABLE COURT:
COME NOW Defendants Ruiz Law Center PLCC and Gustavo C. Ruiz, filing
this, their Motion to Quash both “Plaintiffs’ Notice of Deposition of Defendant,
Gustavo Ruiz” and “Plaintiffs’ Notice of Deposition of Defendant, Ezequiel Reyna,
Jr.” showing as follows:
I.
Basis for Quashing of Notices
On July 29, 2022 counsel undersigned received service of “Plaintiffs’ Notice
of Deposition of Defendant, Gustavo Ruiz” and “Plaintiffs’ Notice of Deposition of
Defendant, Ezequiel Reyna, Jr.”.
The aforementioned deposition notices were unilaterally propounded and gave
randomly selected dates of August 2 nd for the deposition of Reyna and August 3 rd
for the deposition of Ruiz. Counsel undersigned is not available on either date and
Ruiz is not available on August 3 rd .
II.
Quashing of Depositions
[WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3
Electronically Filed
8/1/2022 4:01 PM
Hidalgo County District Clerks
Reviewed By: Edgar Sandoval
WHEREFORE, PREMISES CONSIDERED, and without waiving additional
objection to or relief from the taking of the noticed depositions, including but not
limited to a Motion for Protection, Defendants at this time submit this Motion to
Quash, which, pursuant to the time of its filing in relation to service of the
Deposition Notices, automatically quashes both deposition notices. Rule 199.4, Tex.
R. Civ. Proc.
Respectfully submitted,
A DAMS & G RAHAM , L.L.P.
134 E. Van Buren, Suite 301
Post Office Drawer 1429
Harlingen, Texas 78551-1429
Tel. 956-428-7495
By: _________________________________
W ILLIAM L. P OPE
State Bar No. 16139020
Federal (S. Dist. Tex.) Bar No. 8970
U.S. Tax Court Bar No. PW0378
pope@adamsgraham.com
Counsel for Defendants Ruiz Law Center, PLCC
and Gustavo C. Ruiz
[WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3
Electronically Filed
8/1/2022 4:01 PM
Hidalgo County District Clerks
Reviewed By: Edgar Sandoval
CERTIFICATE OF SERVICE
I hereby certify that on the 1st day of August 2022, a true and correct copy of
the above and foregoing Motion to Quash was forwarded to the following counsel of
record in the indicated fashion, to wit:
Lance Christopher Kassab Via E-Service: lance @kassablaw.com
T HE K ASSAB L AW F IRM Via E-Service: eserve@kassablaw.com
1215 Elgin Street
Houston, Texas 77004
Timothy Micah Dortch Via E-Service: mdortch@potts-law.com
Potts Law Firm, LLP
2911 Turtle Crook, Suite 1000
Dallas, Texas 75219
__________________________________________
WILLIAM L. POPE
[WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3
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: 66854286
Status as of 8/1/2022 4:06 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 8/1/2022 4:01:29 PM SENT
LANCE KASSAB NICHOLAS@KASSAB.LAW 8/1/2022 4:01:29 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: 66854286
Status as of 8/1/2022 4:06 PM CST
Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C.
Name BarNumber Email TimestampSubmitted Status
Timothy MicahDortch mdortch@potts-law.com 8/1/2022 4:01:29 PM SENT
Maryssa JSimpson msimpson@potts-law.com 8/1/2022 4:01:29 PM SENT
Luisa Ulluela lulluela@potts-law.com 8/1/2022 4:01:29 PM SENT
Lance Livingston llivingston@potts-law.com 8/1/2022 4:01:29 PM SENT
MICAH DORTCH MDORTCH@POTTS-LAW.COM 8/1/2022 4:01:29 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: 66854286
Status as of 8/1/2022 4:06 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 8/1/2022 4:01:29 PM SENT
William Pope pope@adamsgraham.com 8/1/2022 4:01:29 PM SENT
Teri Garcia tgarcia@adamsgraham.com 8/1/2022 4:01:29 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: 66854286
Status as of 8/1/2022 4:06 PM CST
Associated Case Party: Ruiz Law Center, PLLC
Name BarNumber Email TimestampSubmitted Status
William L.Pope pope@adamsgraham.com 8/1/2022 4:01:29 PM SENT
Nanci Gracia nancigracia@adamsgraham.com 8/1/2022 4:01:29 PM SENT
Document Filed Date
August 01, 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 8/1/2022 4:01 PM Hidalgo County District Clerks Reviewed By: Edgar Sandoval 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, PLCC and GUSTAVO C. RUIZ’ MOTION TO QUASH TO THE HONORABLE COURT: COME NOW Defendants Ruiz Law Center PLCC and Gustavo C. Ruiz, filing this, their Motion to Quash both “Plaintiffs’ Notice of Deposition of Defendant, Gustavo Ruiz” and “Plaintiffs’ Notice of Deposition of Defendant, Ezequiel Reyna, Jr.” showing as follows: I. Basis for Quashing of Notices On July 29, 2022 counsel undersigned received service of “Plaintiffs’ Notice of Deposition of Defendant, Gustavo Ruiz” and “Plaintiffs’ Notice of Deposition of Defendant, Ezequiel Reyna, Jr.”. The aforementioned deposition notices were unilaterally propounded and gave randomly selected dates of August 2 nd for the deposition of Reyna and August 3 rd for the deposition of Ruiz. Counsel undersigned is not available on either date and Ruiz is not available on August 3 rd . II. Quashing of Depositions [WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3 Electronically Filed 8/1/2022 4:01 PM Hidalgo County District Clerks Reviewed By: Edgar Sandoval WHEREFORE, PREMISES CONSIDERED, and without waiving additional objection to or relief from the taking of the noticed depositions, including but not limited to a Motion for Protection, Defendants at this time submit this Motion to Quash, which, pursuant to the time of its filing in relation to service of the Deposition Notices, automatically quashes both deposition notices. Rule 199.4, Tex. R. Civ. Proc. Respectfully submitted, A DAMS & G RAHAM , L.L.P. 134 E. Van Buren, Suite 301 Post Office Drawer 1429 Harlingen, Texas 78551-1429 Tel. 956-428-7495 By: _________________________________ W ILLIAM L. P OPE State Bar No. 16139020 Federal (S. Dist. Tex.) Bar No. 8970 U.S. Tax Court Bar No. PW0378 pope@adamsgraham.com Counsel for Defendants Ruiz Law Center, PLCC and Gustavo C. Ruiz [WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3 Electronically Filed 8/1/2022 4:01 PM Hidalgo County District Clerks Reviewed By: Edgar Sandoval CERTIFICATE OF SERVICE I hereby certify that on the 1st day of August 2022, a true and correct copy of the above and foregoing Motion to Quash was forwarded to the following counsel of record in the indicated fashion, to wit: Lance Christopher Kassab Via E-Service: lance @kassablaw.com T HE K ASSAB L AW F IRM Via E-Service: eserve@kassablaw.com 1215 Elgin Street Houston, Texas 77004 Timothy Micah Dortch Via E-Service: mdortch@potts-law.com Potts Law Firm, LLP 2911 Turtle Crook, Suite 1000 Dallas, Texas 75219 __________________________________________ WILLIAM L. POPE [WLP/ng]R\R957\Motions & Orders\Def Motion to Quash Page 1 of 3 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: 66854286 Status as of 8/1/2022 4:06 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 8/1/2022 4:01:29 PM SENT LANCE KASSAB NICHOLAS@KASSAB.LAW 8/1/2022 4:01:29 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: 66854286 Status as of 8/1/2022 4:06 PM CST Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C. Name BarNumber Email TimestampSubmitted Status Timothy MicahDortch mdortch@potts-law.com 8/1/2022 4:01:29 PM SENT Maryssa JSimpson msimpson@potts-law.com 8/1/2022 4:01:29 PM SENT Luisa Ulluela lulluela@potts-law.com 8/1/2022 4:01:29 PM SENT Lance Livingston llivingston@potts-law.com 8/1/2022 4:01:29 PM SENT MICAH DORTCH MDORTCH@POTTS-LAW.COM 8/1/2022 4:01:29 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: 66854286 Status as of 8/1/2022 4:06 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 8/1/2022 4:01:29 PM SENT William Pope pope@adamsgraham.com 8/1/2022 4:01:29 PM SENT Teri Garcia tgarcia@adamsgraham.com 8/1/2022 4:01:29 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: 66854286 Status as of 8/1/2022 4:06 PM CST Associated Case Party: Ruiz Law Center, PLLC Name BarNumber Email TimestampSubmitted Status William L.Pope pope@adamsgraham.com 8/1/2022 4:01:29 PM SENT Nanci Gracia nancigracia@adamsgraham.com 8/1/2022 4:01:29 PM SENT