Preview
Electronically Filed
2/15/2023 5:11 PM
Hidalgo County District Clerks
Reviewed By: Lorena Gonzalez
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
DESIGNATION OF EXPERT WITNESSES
TO: Plaintiffs – by and through their counsel of record, to-wit: Lance Christopher Kassab,
The Kassab Law Firm, 1215 Elgin Street, Houston, Texas 77004
COMES NOW, Ruiz Law Center, PLLC and Gustavo C. Ruiz, named as a Defendants in
the above styled and numbered cause, and respectfully submits these, their supplemental initial
disclosures and expert witness designation, in accordance with Rule 195, Tex. R. Civ. Proc. and
the docket control order in this cause.
Said responses are attached hereto and incorporated by reference herein.
Respectfully submitted,
A DAMS & G RAHAM , L.L.P.
134 E. Van Buren, Suite 301
Post Office Drawer 1429
Harlingen, Texas 78551-1429
956/428-7495 (Telephone)
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 Ruiz Defendants
Electronically Filed
2/15/2023 5:11 PM
Hidalgo County District Clerks
Reviewed By: Lorena Gonzalez
CERTIFICATE OF SERVICE
I hereby certify that on the _ 15 th day of February 2023, a true and correct
copy of Defendants Ruiz Law Center, PLLC and Gustavo C. Ruiz’s Designation of Expert
Witnesses, was served upon the following counsel of record, to wit:
Lance Christopher Kassab Via E-Service: eserve@kassablaw.com
THE KASSAB LAW FIRM Via E-Service: lance@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
__________________________________________
DESIGNATION OF EXPERTS
RULE 195.5 EXPERT DISCLOSURES:
(a) The following are disclosed as witnesses with factual, mixed with expert, knowledge
concerning the matters made the basis of this lawsuit; they are not retained experts but parties to
the litigation who possess factual knowledge which, because of the issues presented in this cause,
may also, of necessity, include matters outside the normal knowledge, experience and education
of lay persons and, in an abundance of caution, are therefore disclosed herein, to wit:
(1) Ezequiel Reyna, Jr. – Attorney at Law
c/o Timothy Micah Dortch
Potts Law Firm, LLP
2911 Turtle Crook, Suite 1000
Dallas, Texas 75219
Gustavo (Gus) Ruiz – Attorney at Law
c/o William L. Pope
Adams & Graham, LLP
134 E. Van Buren Avenue, Suite 301
Harlingen, Texas 78551
(2) The above witnesses may testify concerning the usual and ordinary practices, understandings,
agreements, and contracts concerning compensation to healthcare providers, specifically to
Plaintiffs as well as other similar such providers, within the context of ongoing litigation as well
Electronically Filed
2/15/2023 5:11 PM
Hidalgo County District Clerks
Reviewed By: Lorena Gonzalez
as any other situation alluded to in Plaintiffs’ pleadings herein wherein an alleged obligation of
payment is created.
(3) The possible testimony of these witnesses is generally described in (2), above, and since neither
is a retained expert, the basis for such testimony will rest with the documents exchanged by the
parties in discovery, deposition testimony as well as the actual, normal, and ordinary experience
and pattern of practice between these witnesses and the Plaintiffs regarding compensation for
services rendered to the witnesses’ clients. The witnesses will also, of necessity, rely upon their
respective experience as practicing attorneys, which forms the basis, at least in part, of any
interaction with Plaintiffs in the capacity wherein Plaintiffs complain of the Defendants in this
cause.
(4) A, B, C, D, E – Not applicable as the witnesses disclosed above are not retained experts, but
persons with factual knowledge, which when applied to the current allegations of the Plaintiff,
might require testimony including matters not within the realm of lay knowledge.
195.5 (a) : Defendant further designates, as potential expert witness(es), all experts identified or
designated by any other party to this cause of action – without in any fashion attesting to their
qualifications, credibility, veracity or truth, but nonetheless reserving the express right to call any
such experts upon direct, cross or rebuttal examination.
Because any such “cross-designated” experts were not retained by, are not employees of
nor subject to the control of this Defendant, further disclosures are not required.
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: 72810723
Status as of 2/16/2023 9:18 AM 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 2/15/2023 5:11:48 PM SENT
LANCE KASSAB NICHOLAS@KASSAB.LAW 2/15/2023 5:11:48 PM SENT
Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C.
Name BarNumber Email TimestampSubmitted Status
Maryssa JSimpson msimpson@potts-law.com 2/15/2023 5:11:48 PM SENT
Luisa Ulluela lulluela@potts-law.com 2/15/2023 5:11:48 PM SENT
Lance Livingston llivingston@potts-law.com 2/15/2023 5:11:48 PM SENT
MICAH DORTCH MDORTCH@POTTS-LAW.COM 2/15/2023 5:11:48 PM SENT
Associated Case Party: Ruiz Law Center, PLLC
Name BarNumber Email TimestampSubmitted Status
William L.Pope pope@adamsgraham.com 2/15/2023 5:11:48 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 2/15/2023 5:11:48 PM SENT
Tristan Clark tclark@adamsgraham.com 2/15/2023 5:11:48 PM SENT
MICAH DORTCH DORTCH-MDORTCH@POTTS-LAW.COM 2/15/2023 5:11:48 PM ERROR
Preview
Electronically Filed 2/15/2023 5:11 PM Hidalgo County District Clerks Reviewed By: Lorena Gonzalez 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 DESIGNATION OF EXPERT WITNESSES TO: Plaintiffs – by and through their counsel of record, to-wit: Lance Christopher Kassab, The Kassab Law Firm, 1215 Elgin Street, Houston, Texas 77004 COMES NOW, Ruiz Law Center, PLLC and Gustavo C. Ruiz, named as a Defendants in the above styled and numbered cause, and respectfully submits these, their supplemental initial disclosures and expert witness designation, in accordance with Rule 195, Tex. R. Civ. Proc. and the docket control order in this cause. Said responses are attached hereto and incorporated by reference herein. Respectfully submitted, A DAMS & G RAHAM , L.L.P. 134 E. Van Buren, Suite 301 Post Office Drawer 1429 Harlingen, Texas 78551-1429 956/428-7495 (Telephone) 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 Ruiz Defendants Electronically Filed 2/15/2023 5:11 PM Hidalgo County District Clerks Reviewed By: Lorena Gonzalez CERTIFICATE OF SERVICE I hereby certify that on the _ 15 th day of February 2023, a true and correct copy of Defendants Ruiz Law Center, PLLC and Gustavo C. Ruiz’s Designation of Expert Witnesses, was served upon the following counsel of record, to wit: Lance Christopher Kassab Via E-Service: eserve@kassablaw.com THE KASSAB LAW FIRM Via E-Service: lance@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 __________________________________________ DESIGNATION OF EXPERTS RULE 195.5 EXPERT DISCLOSURES: (a) The following are disclosed as witnesses with factual, mixed with expert, knowledge concerning the matters made the basis of this lawsuit; they are not retained experts but parties to the litigation who possess factual knowledge which, because of the issues presented in this cause, may also, of necessity, include matters outside the normal knowledge, experience and education of lay persons and, in an abundance of caution, are therefore disclosed herein, to wit: (1) Ezequiel Reyna, Jr. – Attorney at Law c/o Timothy Micah Dortch Potts Law Firm, LLP 2911 Turtle Crook, Suite 1000 Dallas, Texas 75219 Gustavo (Gus) Ruiz – Attorney at Law c/o William L. Pope Adams & Graham, LLP 134 E. Van Buren Avenue, Suite 301 Harlingen, Texas 78551 (2) The above witnesses may testify concerning the usual and ordinary practices, understandings, agreements, and contracts concerning compensation to healthcare providers, specifically to Plaintiffs as well as other similar such providers, within the context of ongoing litigation as well Electronically Filed 2/15/2023 5:11 PM Hidalgo County District Clerks Reviewed By: Lorena Gonzalez as any other situation alluded to in Plaintiffs’ pleadings herein wherein an alleged obligation of payment is created. (3) The possible testimony of these witnesses is generally described in (2), above, and since neither is a retained expert, the basis for such testimony will rest with the documents exchanged by the parties in discovery, deposition testimony as well as the actual, normal, and ordinary experience and pattern of practice between these witnesses and the Plaintiffs regarding compensation for services rendered to the witnesses’ clients. The witnesses will also, of necessity, rely upon their respective experience as practicing attorneys, which forms the basis, at least in part, of any interaction with Plaintiffs in the capacity wherein Plaintiffs complain of the Defendants in this cause. (4) A, B, C, D, E – Not applicable as the witnesses disclosed above are not retained experts, but persons with factual knowledge, which when applied to the current allegations of the Plaintiff, might require testimony including matters not within the realm of lay knowledge. 195.5 (a) : Defendant further designates, as potential expert witness(es), all experts identified or designated by any other party to this cause of action – without in any fashion attesting to their qualifications, credibility, veracity or truth, but nonetheless reserving the express right to call any such experts upon direct, cross or rebuttal examination. Because any such “cross-designated” experts were not retained by, are not employees of nor subject to the control of this Defendant, further disclosures are not required. 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: 72810723 Status as of 2/16/2023 9:18 AM 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 2/15/2023 5:11:48 PM SENT LANCE KASSAB NICHOLAS@KASSAB.LAW 2/15/2023 5:11:48 PM SENT Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C. Name BarNumber Email TimestampSubmitted Status Maryssa JSimpson msimpson@potts-law.com 2/15/2023 5:11:48 PM SENT Luisa Ulluela lulluela@potts-law.com 2/15/2023 5:11:48 PM SENT Lance Livingston llivingston@potts-law.com 2/15/2023 5:11:48 PM SENT MICAH DORTCH MDORTCH@POTTS-LAW.COM 2/15/2023 5:11:48 PM SENT Associated Case Party: Ruiz Law Center, PLLC Name BarNumber Email TimestampSubmitted Status William L.Pope pope@adamsgraham.com 2/15/2023 5:11:48 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 2/15/2023 5:11:48 PM SENT Tristan Clark tclark@adamsgraham.com 2/15/2023 5:11:48 PM SENT MICAH DORTCH DORTCH-MDORTCH@POTTS-LAW.COM 2/15/2023 5:11:48 PM ERROR