Preview
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
MOORE
MA lN * HO ON
June 22, 2022
Via-Hand Delivery To Chambers & E-File
Honorable Judge David Sanchez
MDL Pretrial Judge
District Judge, 444th District Court
Cameron County Court House
974 E. Harrison St.
Brownsville, Texas 78520
Re: Cause No: MDL 15-0360; In re: Fraudulent Hospital Lien Litigation; In the
444th Judicial District Court (Pretrial Court) of Cameron County, Texas;
And,
Cause No.: C-2540-19-L; Baldemar Quintero, Jr. vs. Signature Care, et al;
In the 464th Judicial District Court of Hidalgo County, Texas;
Cause No.: C-2542-19-L; Karina Quintero vs. Signature Care, et al; In the
464th Judicial District Court of Hidalgo County, Texas;
Cause No.: C-2541-19-L; Maria Quintero vs. Signature Care, et al., In the 464th
Judicial District Court of Hidalgo County, Texas; and,
Cause No. C-2543-19-H; Edgar Perez vs. Signature Care, et al.; In the 389th
Judicial District Court of Hidalgo County, Texas.
Dear Judge Sanchez:
Per your instructions during the status hearing today, I am attaching the
Plaintiffs’ Proposed Order Vacating Prior Orders Granting Transfer to Fort Bend
County, Texas and Order of Remand to Originating Courts Without prejudice to
Right to Transfer by the Proper MDL Court, with Exhibits A: The MDL Panel Order
and Exhibit B: Orders Vacated for your consideration.
As discussed during the status conference, Rule 13.6(a) which reads in
relevant part “. . . The Judge assigned as judge of the pretrial court has exclusive
jurisdiction over each related case transferred pursuant to this rule unless a case is
4900 North 10th, Suite F-3 · McAllen, Texas 78504
Tel. 956.631-0745 · Fax. 888.266.0971
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Honorable Judge David Sanchez Reviewed By: Adrienne Rocha
MDL Pretrial Judge
District Judge, 444th District Court
June 22, 2022
Page 2 of 2
__________________________________________
transferred by the MDL Panel or is finally resolved or remanded to the trial court
for trial.” Rules of Judicial Administration, Rule 13 Multidistrict Litigation.
Since the Panel concluded on November 15, 2021 [See, Exhibit A attached to
the Proposed Order] that the case of Terrance Williams vs. SignatureCare was not
related to the other cases in In re: Fraudulent Hospital Lien Litigation, the same is
true for each of the cases referenced above, they are not related, and therefore per
Rule 13.6(a), this Court is without jurisdiction to transfer the SignatureCare cases to
an unspecified court in Fort Bend County, Texas on a venue challenge. Id. Also,
since the Panel assigned all cases involving lien disputes against SignatureCare and
Round Table to the Hon. Judge Mark Davidson by Order dated October 11, 2019, in
Case No. MDL 19-0499; In re: Freestanding Emergency Medical Care facilities
Lien Litigation Judge Davidson as the Pretrial Court, and the above cases are related,
Judge Davidson of the 334th District Court of Harris County, Texas would have
exclusive jurisdiction to hear a motion to transfer venue only after the cases are
tagged into that MDL from the originating trial court. See, Order of the Panel
attached, and see, Id. Rule 13.6(a). At the time of the entry of this Court’s Orders
for each of the unrelated cases on November 10, 2021, the Panel had already issued
its orders of transfer for the Signature Care Round Table Lien disputes a month
earlier, and subsequently appointed the Hon. Honorable Steven Kirkland on October
11, 2019, and thereafter the Hon. Mark Davidson as the MDL Pretrial Court Judge
on December 20, 2021.
It is respectfully submitted that the attached order remanding these unrelated
cases referenced above back to the originating trial courts in Hidalgo County, Texas
is the only issue this MDL Pretrial Court has jurisdiction to do, and thereafter the
cases can then be tagged into the proper MDL as related cases and Judge Davidson
can then consider any motions to transfer the case based upon venue considerations
since his Court is the only Court having jurisdiction to decide such pretrial matters
per Rule 13.6(a).
Should the Court require any additional information, please so advise. By
copy of this transmittal letter, all parties are being notified of this action.
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Honorable Judge David Sanchez Reviewed By: Adrienne Rocha
MDL Pretrial Judge
District Judge, 444th District Court
June 22, 2022
Page 3 of 2
__________________________________________
Respectfully Submitted,
MOORE LAW FIRM
/s/ J. Michael Moore
J. Michael Moore
Cc: Via E-File Service to All Counsel of Record
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
CAUSE NO. MDL-15-0360
In re: § IN THE DISTRICT COURT
§
FRAUDULENT HOSPITAL LIEN §
LITIGATION. §
§ 444m JUDICIAL DISTRICT
§ (MDL PRETRIAL COURT)
§
§
§ CAMERON COUNTY, TEXAS
CAUSE NO. C-2540-19-L
BALDEMAR QUINTERO, JR., § IN THE DISTRICT COURT
Plaintiff, §
§
v. §
§ 464TH JUDICAL DISTRICT
SIGNATURE CARE EMERGENCY §
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, P.L.L.C., §
Defendants. § HIDALGO COUNTY, TEXAS
CAUSE NO. C-2542-19-L
KARINA QUINTERO, § IN THE DISTRICT COURT
Plaintiff, §
§
v. §
§
§ 464th JUDICIAL DISTRICT
SIGNATURE CARE EMERGENCY
§
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, §
Defendant § HIDALGO COUNTY, TEXAS
ORDER VACATING PRIOR ORDERS GRANTING TRANSFER TO FORT BEND COUNTY, TEXAS
AND ORDER OF REMAND TO ORIGINATING TRIAL COURTS WITHOUT PREJUDICE TO RIGHT
TO TRANSFER BY THE PROPER MDL COURT
Page 1
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
CAUSE NO. C-2541-19-L
MARIA QUINTERO, § IN THE DISTRICT COURT
Plaintiff, §
§
§
v. §
§
SIGNATURE CARE EMERGENCY § 464th JUDICIAL DISTRICT
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, §
Defendant § HIDALGO COUNTY, TEXAS
CAUSE NO. C-2543-19-H
EDGAR PEREZ, § IN THE DISTRICT COURT
Plaintiff, §
§
v. §
§
SIGNATURE CARE EMERGENCY § 389th JUDICIAL DISTRICT
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, §
Defendant § HIDALGO COUNTY, TEXAS
ORDER VACATING PRIOR ORDERS GRANTING TRANSFER TO FORT BEND
COUNTY, TEXAS AND ORDER OF REMAND TO ORIGINATING TRIAL COURTS
WITHOUT PREJUDICE TO RIGHT TO TRANSFER BY THE PROPER MDL COURT
BE IT REMEMBERED that on the 22nd day of June, 2022, this Court held a
status hearing on the above referenced matters; the Court, after hearing arguments of
counsel and reviewing Orders of the MDL Panel, pleadings and motions on file, finds that
the cases of Baldemar Quintero, Jr. vs. Signature Care, et al, pending in Cause No.: C-
2540-19-L; Hidalgo County, Texas; Karina Quintero vs. Signature Care, et al., pending in
Cause No.: C-2542-19-L; Hidalgo County, Texas; Maria Quintero vs. Signature Care, et
ORDER VACATING PRIOR ORDERS GRANTING TRANSFER TO FORT BEND COUNTY, TEXAS
AND ORDER OF REMAND TO ORIGINATING TRIAL COURTS WITHOUT PREJUDICE TO RIGHT
TO TRANSFER BY THE PROPER MDL COURT
Page2
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
al., pending in Cause No.: C-2541-19-L and Edgar Perez vs. Signature Care, et al. pending
in Cause No.: C-2543-19-H; Hidalgo County, Texas were improperly tagged and
transferred from their originating courts into In re: Fraudulent Hospital Lien Litigation,
Cause No.: MDL-15-0360, pending in this the 444th Judicial District Court, Cameron
County, Texas as per the Opinion and Order issued by the Multidistrict Litigation Panel on
September 26, 2019, a copy of which is attached to this Order, as Exhibit A; and, therefore:
IT IS ORDERED, ADJUDGED AND DECREED, that the prior Orders Granting
Signature Care Emergency Center (Sugarland Mission Bend Emergency Center LLC) and
Round Table Physicians Group PLLC's Motion to Transfer Venue issued on November
10, 2021, [attached to this Order as Exhibit B], are hereby vacated/rescinded, without
prejudice to the re-urging of same in the proper MDL Pretrial Court before the Honorable
Pretrial Court Judge Mark Davidson, MDL 10-0499/Master Docket No. 2019-77967,
styled In re: Freestanding Emergency Medical Facilities Lien Litigation, In the 334th
District Court of Harris County, Texas.
IT IS FURTHER ORDERED that Baldemar Quintero, Jr. vs. Signature Care, et
al, pending in Cause No.: C-2540-19-L; Hidalgo County, Texas; Karina Quintero vs.
Signature Care, et al., pending in Cause No.: C-2542-19-L; Hidalgo County, Texas; Maria
Quintero vs. Signature Care, et al., pending in Cause No.: C-2541-19-L and Edgar Perez
vs. Signature Care, et al. pending in Cause No.: C-2543-19-H; Hidalgo County are hereby
REMANDED and out of In re: Fraudulent Hospital Lien Litigation, Cause No.: MDL-15-
0360, pending in the 444th Judicial District Court, Cameron County, Texas and
TRANSFERRED back to their originating courts as listed herein.
ORDER VACATING PRIOR ORDERS GRANTING TRANSFER TO FORT BEND COUNTY, TEXAS
AND ORDER OF REMAND TO ORIGINATING TRIAL COURTS WITHOUT PREJUDICE TO RIGHT
TO TRANSFER BY THE PROPER MDL COURT
Page3
Electronically Filed
6/23/2022 9:34 AM
Hidalgo County District Clerks
Reviewed By: Adrienne Rocha
SIGNED this _ _ day of - - - - - 2022.
Hon. David Sanchez
MDL Pretrial Court
Judge, 444 th District Court
CC:
J. Michael Moore
Moore law firm
Telecopier: (888) 266-0971
mmoore@moore-firm.com
fhl-docket@moore-firm.com
Mr. Christopher Demeo
cdemeo@seyfarth.com
Ms. Kay Hazelwood
khazel wood(a),seyfarth.com
Seyfarth Shaw LLP
Facsimile: (713) 225-2340
Ms. Melanie Rubinsky
mrubinsky(a),sprottnewsom.com
Sprott, Newsom, Quattlebaum
& Messenger, PC
Facsimile (713) 523-9422
ORDER VACA TING PRIOR ORDERS GRANTING TRANSFER TO FORT BEND COUNTY, TEXAS
AND ORDER OF REMAND TO ORIGINATING TRIAL COURTS WITHOUT PREJUDICE TO RIGHT
TO TRANSFER BY THE PROPER MDL COURT
Page 4
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.
J. Michael Moore
Bar No. 14349550
mmoore@moore-firm.com
Envelope ID: 65702007
Status as of 6/23/2022 10:26 AM CST
Associated Case Party: SIGNATURE CARE EMERGENCY CENTER
Name BarNumber Email TimestampSubmitted Status
Melanie Rubinsky mrubinsky@sprottnewsom.com 6/23/2022 9:34:42 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Kay Hazelwood Khazelwood@Seyfarth.com 6/23/2022 9:34:42 AM SENT
FHL DOCKET FHL-DOCKET@MOORE-FIRM.COM 6/23/2022 9:34:42 AM SENT
Lit Docket lit-docket@moore-firm.com 6/23/2022 9:34:42 AM SENT
Chris DeMeo cdemeo@seyfarth.com 6/23/2022 9:34:42 AM SENT
Roger Donnellan rdonnellan@seyfarth.com 6/23/2022 9:34:42 AM SENT
Hou Docket HOUDocket@seyfarth.com 6/23/2022 9:34:42 AM SENT