Motion for Change of Venue in EDGAR PEREZ vs. SIGNATURE CARE EMERGENCY CENTER,Round Table Physicians Group, PLLC| Trellis.Law

On June 07, 2019 a Motion,Ex Parte was filed involving a dispute between Perez, Edgar, and Round Table Physicians Group, Pllc, Signature Care Emergency Center, for CPRC Chapter 12 in the District Court of Hidalgo County.

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Electronically Filed
FILED7/25/2022
- 3/8/20221:56
4:14PM
PM
MDL-15-0360 / 62422320
Hidalgo County District Clerks
LAURA PEREZ-REYES
Reviewed By: Adrienne Rocha
Cameron County District Clerk
By Claudia Palacios Deputy Clerk
MDL NO. 15-0360

CAUSE NO. 2018-91391

In Re: § IN THE DISTRICT COURT OF
§
FRAUDULENT HOSPITAL §
LIEN LITIGATION. §
§ 444th JUDICIAL DISTRICT
§ (MDL PRETRIAL COURT)
§
§
§
§ CAMERON COUNTY, TEXAS
__________________________________________________________________

CAUSE NO. C-2540-19-L

BALDEMAR QUINTERO, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
vs. § 464th JUDICIAL DISTRICT
§
SIGNATURE CARE EMERGENCY §
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, § HIDALGO COUNTY, TEXAS
§
Defendants. §
§
CAUSE NO. C-2541-19-L

MARIA QUINTERO, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
vs. § 464th JUDICIAL DISTRICT
§
SIGNATURE CARE EMERGENCY §
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, § HIDALGO COUNTY, TEXAS
§
Defendants. §
§

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CAUSE NO. C-2542-19-L

KARINA QUINTERO, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
vs. § 464th JUDICIAL DISTRICT
§
SIGNATURE CARE EMERGENCY §
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, § HIDALGO COUNTY, TEXAS
§
Defendants. §
§
CAUSE NO. C-2543-19-H

EDGAR PEREZ, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
vs. § 389th JUDICIAL DISTRICT
§
SIGNATURE CARE EMERGENCY §
CENTER AND ROUND TABLE §
PHYSICIANS GROUP, PLLC, § HIDALGO COUNTY, TEXAS
§
Defendants. §
§

DEFENDANTS,’ SUGARLAND MISSION BEND EMERGENCY CENTER PLLC D/B/A
SIGNATURE CARE EMERGENCY CENTER AND
ROUND TABLE PHYSICIANS GROUP, PLLC, JOINT RESPONSE TO MOTION FOR
CLARIFICATION CONCERNING ORDER GRANTING DEFENDANTS’
MOTION TO TRANSFER VENUE AND MOTION FOR REMAND

Sugarland Mission Bend Emergency Center PLLC d/b/a Signature Care Emergency Center

(“Signature Care”) and Round Table Physicians Group, PLLC (“Round Table”) file this Joint

Response to the Motion for Clarification Concerning Order Granting Defendants’ Motion to

Transfer Venue and respectfully show this Court as follows:

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I. Introduction

Plaintiffs are asking this Court to reconsider its order transferring these cases to Fort Bend

County on the pretext of seeking “clarification.” The Court should deny this motion because (1)

this Court does not have jurisdiction to re-consider its ruling — thirty days after a case is

transferred, the transferring court no longer has jurisdiction (2) this Court’s status as an MDL court

does not extend this court’s plenary power to reconsider its ruling—Rule 87 prohibits a second

motion to transfer venue and precludes reconsideration of a previous ruling and (3) even if this

Court had jurisdiction to reconsider its prior ruling on venue, this Court is not required to make

findings of fact so clarification of the Court’s orders is unwarranted. Finally, as this Court noted

in the status conference in November, these cases do not belong in this MDL and should instead

be part of the Harris County MDL. In order to effectuate that transfer, Defendants request that this

Court remand these proceedings to Fort Bend County so that these cases may be tagged into the

Harris County MDL. Orders remanding this case to Fort Bend County are attached.

II. Factual and Procedural Background

These cases were initially filed in Hidalgo County in June 2019 and were then tagged into

this MDL. On July 9,2019, Defendants filed motions to transfer venue of these cases to Fort Bend

County and set their motions for a hearing. The Plaintiffs did not file a timely response; on

September 24, 2019, the day before the hearing, Plaintiffs filed a motion for continuance and

motion for leave to file a late response. On September 25, 2019, after considering Plaintiffs

motions, this Court heard the Defendants’ motions. At the conclusion of the hearing, this Court

stated that it would only consider the plaintiffs’ pleadings when ruling on the motions to transfer

but asked the parties to consider settlement. Ex. A, Hearing Transcript, p. 45. The following day,

the Supreme Court provided clarification of the scope of this MDL and ruled that only cases

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involving McAllen Medical Center should be joined here. These cases did not settle so on

November 10, 2021, Defendants asked this Court to rule on their motions to transfer venue during

the Court’s status conference. The Court granted those motions and signed conforming orders on

November 15, 2021. These orders were circulated by email to counsel by the clerk of Cameron

County. Ex. E, Transfer Orders. On January 6, 2022, Plaintiffs filed their motion for clarification.

III. Argument and Authorities

A. This Court does not have jurisdiction to reconsider its venue orders.

On a motion to transfer, a court only has thirty days to reconsider its ruling. In re Team

Rocket, L.P., 256 S.W.3d 257, 259 (Tex. 2008) (orig. proceeding); In re Sw. Bell Tel. Co., 35

S.W.3d 602, 605 (Tex. 2000) (per curiam). Motions for clarification or reconsideration do not

extend the trial court’s jurisdiction to vacate or reconsider its order. In re Chester, 309 S.W.3d

713, 718 (Tex. App. - Houston [14th Dist.] 2010, orig. proceeding) (Rule 329b(e) of the Texas

Rules of Civil Procedure does not apply to extend jurisdiction of motions to transfer venue); In re

Gibbs, No. 06-15-00002-CV, 2015 WL 400468, at *1 (Tex. App.—Texarkana, Jan. 30, 2015, orig.

proceeding) (fact that motion to reconsider was filed during trial court’s plenary jurisdiction is of

no consequence; trial court lost jurisdiction to reconsider venue thirty days after its ruling).

Although a trial court’s ruling is interlocutory as to the parties, it is final for the transferring court

after its plenary power expires. Id. Accordingly, this Court does not have jurisdiction to reconsider

or clarify its prior orders and Plaintiffs’ motion must be denied.1

1
Even if some equitable basis existed for extending this Court’s plenary power because plaintiffs did not receive
notice of the orders until December 30, 2021, their motion was not filed and heard within 30 days of the date they
admitted they were aware of the Court’s Order.

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B. This Court’s status as an MDL pretrial court does not extend this Court’s jurisdiction
to clarify or reconsider its venue orders.

Because these cases were tagged into this MDL, this Court sits in the peculiar position of

being the pretrial court before and after the motion to transfer has been granted. As the transferring

court, this court loses jurisdiction to modify its orders after thirty days. See supra. As the transferee

court, this court does not have jurisdiction to reconsider a motion to transfer venue. Rule 87 (5)

provides that where venue has been sustained or if an action has been transferred in response to a

motion to transfer venue, no further motions may be considered. Tex. R. Civ. P. 87 (5). Under

rule 87, the trial court (if denied) cannot consider another motion to transfer and the subsequent

court (if granted) cannot reconsider a motion to transfer. In re Lowes Home Ctr., LLC, 531 S.W.3d

861, 870 (Tex. App. — Corpus Christi-Edinburg, 2017, orig. proceeding) (it is clear the rule

prohibits a subsequent trial court from making its own venue determination); Fincher v. Wright,

141 S.W.3d 255, 264 (Tex. App. — Fort Worth, 2004, no pet.) (only one venue determination may

be made in a single proceeding). Rule 87 specifically precludes this court from reconsidering its

prior ruling. Tex. R. Civ. P. 87 (5). For this additional reason, Plaintiffs’ motion must be denied.

C. No rule requires findings and the Plaintiffs cite no authority to support their position
to the contrary.

Finally, Plaintiffs argue that this Court’s order needs to be clarified under Section 15.002(b)

of the Texas Civil Practice and Remedies Code and this Court must make findings as to its venue

determination. See Joint Mtn. at pp. 10 - 11. Even if this Court had jurisdiction to grant that relief,

there is no rule, statute or case that suggests this Court’s order must include findings. “The Texas

Civil Practice and Remedies Code does not explicitly require the findings to be set out in the

order.” In re Gibbs, 2015 WL 400468, at *3. In addition, Rule 28.1 provides that the trial court

need not file findings of fact or conclusions of law with respect to interlocutory orders. Tex. R.

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App. P. 28.1(c). This Court did not make findings of fact because it was not required to do so. For

this additional reason, the Plaintiffs’ motion should be denied.

D. Alternatively, the Defendants specifically denied the Plaintiffs’ pleaded venue facts
and the Plaintiffs failed to proffer prima facie proof supporting their choice of venue.

If a defendant challenges the plaintiff’s choice of venue, the plaintiff has the burden to

proffer prima facie proof that venue is maintainable in the county of the suit. Tex. R. Civ. P.

87(2)(a), 3(a). In the present case, Defendants offered evidence that mandatory venue exists in

Fort Bend County. If this Court has jurisdiction to entertain the Plaintiffs’ motion, this Court

should conclude, again, that venue is not proper in Hidalgo County and these cases should remain

in Fort Bend County.

Alternatively, Defendants established that venue is proper in Fort Bend County under

section 15.002. The plaintiffs relied on the general venue statue and argued that all or a substantial

part of the events giving rise to their claims occurred in Hidalgo County. In response, the

Defendants specifically denied that allegation, thus requiring the plaintiffs to make prima facie

showing. Ex. B, Mtn. pp. 3-4. Devon Energy Corp. v. Iona Energy, L.P., No. 02-19-00343-CV,

2020 WL 98138, at *8 (Tex. App.—Fort Worth Jan. 9, 2020, pet. filed) (mem. op.) (where

defendant specifically denies that a substantial part of the acts and omissions occurred in county

where plaintiff filed suit, plaintiff is required to prove venue is proper in county where suit is filed);

Landco Enters. v. Jindal Saw USA, LLC, No. 01-19-00797-CV, 2020 WL 4457971, at *1 (Tex.

App.—Houston [1st Dist.] Aug. 4, 2020, no pet.)(memorandum op.) (same).

In the instant case, Defendants specifically denied that a substantial part of the acts or

omissions giving rise to the underlying claims occurred in Hidalgo County and then went on to

parse those elements of the plaintiffs’ claims and contended they did not occur in Hidalgo County

but instead occurred in Harris and Fort Bend County. Specifically, Defendants established that:

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(1) the liens were not filed in Hidalgo County; the liens were filed in Fort Bend County; (2) the

Plaintiffs were not treated in Hidalgo County; they were injured and treated in Fort Bend County;

(3) Defendants do not have any facilities in Hidalgo County; their facilities are in Fort Bend

County; (4) Defendants principal place of business is not in Hidalgo County; it is in Harris County

(5) any communications with plaintiff or their counsel did not occur in Hidalgo County; they

occurred from their facilities in Fort Bend County or from their offices in Harris County.2 For

similar reasons, Hidalgo County is not a convenient forum as demonstrated in the affidavit of Lisa

Snyder. Ex. D, Mtn to Transfer, Ex. A.

The defendants denials and evidence directed to the Plaintiffs’ reliance on section

15.002(1) were not mere general denials; they were denials of the alleged venue facts themselves

and were specific enough to provide notice to the plaintiff. Once challenged, as here, the Court

cannot accept as true the facts plead in the Petition. Instead, the plaintiff must offer prima facie

evidence supporting its choice of venue. Id. They failed to do so. Because the Plaintiffs offered no

evidence in support of their venue facts, they failed to meet their burden under Rule 87 and the

Court should deny the Plaintiffs’ motion.

E. These cases should be remanded to Fort Bend County so that they can be included in
the Harris County MDL.

Concurrent with, but subject to, the Motion to Transfer Venue, the Defendants filed a

Motion to Remand these cases to Fort Bend County. Ex. B, Mtn. to Remand (without Exhibits).

This Motion was previously discussed on September 25, 2019 when this Court heard the

Defendants’ Motions to Transfer Venue. See Ex. A, Transcript, pp. 18-19, 23-25. As noted in their

motion, these cases should not be in this MDL; instead these cases belong in a Harris County

2
These venue facts were supported by affidavit. See e.g., Mtn. to Transfer Venue, Ex. A, filed on July 8, 2019,
attached as Ex. D. An identical motion was filed in each case.

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MDL.3 On September 26, 2019, the MDL Panel clarified that this MDL is limited to hospital lien

cases and tag-along cases filed in Hidalgo County against McAllen Hospitals and affiliated

hospitals. Ex. C. These Defendants are not affiliates of McAllen Hospital so these cases should be

remanded from this MDL to the district court in Fort Bend County where they were transferred.

Defendants renew their motion and request that this Court grant their motion to remand each of

these cases to the Fort Bend County Judicial District Court in which they are pending.

Defendants respectfully request that this Court deny the Joint Motion for Clarification filed

by the Plaintiffs and grant the Joint Motion to Remand these cases to the respective district court

in Fort Bend County and for such other relief to which they may be entitled.

3
The Harris County MDL was created on October 11, 2019 for all cases filed against the Signature Care Emergency
Centers and/or Round Table in Harris or Fort Bend counties.

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DATED: March 8, 2022 Respectfully submitted,

SEYFARTH SHAW LLP

By: /s/ Kay J. Hazelwood
Christopher D. DeMeo
Texas Bar No. 00796456
cdemeo@seyfarth.com
Kay Hazelwood
Texas Bar No. 09310450
khazelwood@seyfarth.com
Andrew P. del Junco
Texas Bar No. 24097585
adeljunco@seyfarth.com
700 Milam, Suite 1400
Houston, TX 77002
Telephone: (713) 225-0292
Facsimile: (713) 225-2340

Melanie Rubinsky
Texas Bar No. 50511615
SPROTT, NEWSOM, QUATTLEBAUM
& MESSENGER, P.C.
2211 Norfolk Street, Suite 1150
Houston, TX 77098
Telephone: (713) 523-8338
Facsimile (713) 523-9422
mrubinsky@sprottnewsom.com

ATTORNEYS FOR SUGARLAND MISSION
BEND EMERGENCY CENTER, PLLC AND
ROUND TABLE PHYSICIANS GROUP,
PLLC

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CERTIFICATE OF SERVICE

I hereby certify that pursuant to Rules 21 and 21a of the Texas Rules of Civil Procedure on
March 8, 2022, a true and correct copy of this submission was served on all opposing counsel by
approved electronic filing service including:

Moore Law Firm
J. Michael Moore
4900 North 10th Street, Suite F3
McAllen, Texas 78504
ATTORNEYS FOR PLAINTIFF

/s/ Kay J. Hazelwood
Kay J. Hazelwood

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80358785v.1
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Hidalgo County District Clerks
Automated Certificate of eService Reviewed By: Adrienne Rocha
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.

Melody Agrait on behalf of Melanie Rubinsky
Bar No. 50511615
magrait@sprottnewsom.com
Envelope ID: 62422320
Status as of 3/9/2022 8:07 AM CST

Associated Case Party: Fraudulent Hospital Lien Litigation

Name BarNumber Email TimestampSubmitted Status

Lit Docket lit-docket@moore-firm.com 3/8/2022 5:02:28 PM SENT

Pablo Garza III pablo@gg-attorneys.com 3/8/2022 5:02:28 PM SENT

Kimberly M.Garcia kimberly@gg-attorneys.com 3/8/2022 5:02:28 PM SENT

J. MichaelMoore fhl-docket@moore-firm.com 3/8/2022 5:02:28 PM SENT

Victor Ramirez victorramirezatty@me.com 3/8/2022 5:02:28 PM SENT

R. James Amaro fax@amarolawfirm.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: McAllen Hospitals, LP

Name BarNumber Email TimestampSubmitted Status

Mr. Lawrence Rothenberg Mr. Lawrence Rothenberg rothenber2@gmail.com 3/8/2022 5:02:28 PM SENT

Mr. James Mcgregor, JR. Witt McGregor & Courland, . jmcgregor@wmbwaco.com 3/8/2022 5:02:28 PM SENT

Patrick B Patrick.Bredehoft@tklaw.com 3/8/2022 5:02:28 PM SENT

Mr. Andrew Cookingham . Andrew.Cookingham@tklaw.com 3/8/2022 5:02:28 PM SENT

Joel Mohrman joel.mohrman@akerman.com 3/8/2022 5:02:28 PM SENT

Andy Cao andy.cao@akerman.com 3/8/2022 5:02:28 PM SENT

Sean Santarelli sean.santarelli@akerman.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Alegis Revenue Group, LLC

Name BarNumber Email TimestampSubmitted Status

Douglas Turek dturek@tureklawfirm.com 3/8/2022 5:02:28 PM SENT

Erin Lowinske elowinske@tureklawfirm.com 3/8/2022 5:02:28 PM ERROR

Amy Kogan akogan@tureklawfirm.com 3/8/2022 5:02:28 PM ERROR

Associated Case Party: Turek Devore, P.C.
Electronically Filed
7/25/2022 1:56 PM
Hidalgo County District Clerks
Automated Certificate of eService Reviewed By: Adrienne Rocha
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.

Melody Agrait on behalf of Melanie Rubinsky
Bar No. 50511615
magrait@sprottnewsom.com
Envelope ID: 62422320
Status as of 3/9/2022 8:07 AM CST

Associated Case Party: Turek Devore, P.C.

Name BarNumber Email TimestampSubmitted Status

Christopher MichaelKarl ckarl@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Katie Guerrero kguerrero@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Samantha Coker scoker@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Sharon Luce sluce@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Robert E.Valdez revaldez@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Laredo Texas Hospital Company, L.P. D/B/A Laredo Medical
Center

Name BarNumber Email TimestampSubmitted Status

Taylor FitzGerrell tfitzgerrell@serpejones.com 3/8/2022 5:02:28 PM SENT

Robert E.Bell rbell@serpejones.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Northwest Texas Healthcare System, Inc.

Name BarNumber Email TimestampSubmitted Status

Douglas Turek dturek@tureklawfirm.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Amber Rodriguez

Name

Aida Moralez

rogelio solis

Jared A.Clark

Sonia Maupin
Electronically Filed
7/25/2022 1:56 PM
Hidalgo County District Clerks
Automated Certificate of eService Reviewed By: Adrienne Rocha
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.

Melody Agrait on behalf of Melanie Rubinsky
Bar No. 50511615
magrait@sprottnewsom.com
Envelope ID: 62422320
Status as of 3/9/2022 8:07 AM CST

Associated Case Party: Amber Rodriguez

Francisco JRodriguez frankr@mcallenlawfirm.com 3/8/2022 5:02:28 PM SENT

Danielle CRodriguez danielle@mcallenlawfirm.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: MEDDATA D/B/A ALEGIS REVENUE GROUP, LLC

Name BarNumber Email TimestampSubmitted Status

Geoffery Gannaway ggannaway@beckredden.com 3/8/2022 5:02:28 PM SENT

Jackie Furlow jfurlow@beckredden.com 3/8/2022 5:02:28 PM SENT

Cassie Maneen cmaneen@beckredden.com 3/8/2022 5:02:28 PM SENT

Allison StandishMiller amiller@beckredden.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: TC JESTER EC, LLC D/B/A SIGNATURE CARE
EMERGENCY CENTER

Name BarNumber Email TimestampSubmitted Status

Melanie Ann Rubinsky 50511615 mrubinsky@sprottnewsom.com 3/8/2022 5:02:28 PM SENT

Christopher D.DeMeo cdemeo@seyfarth.com 3/8/2022 5:02:28 PM SENT

Kay Hazelwood khazelwood@seyfarth.com 3/8/2022 5:02:28 PM SENT

Case Contacts

Name

Frank XJoyce

Nicholas Pena

Chris DeMeo

Juan JHinojosa
Electronically Filed
7/25/2022 1:56 PM
Hidalgo County District Clerks
Automated Certificate of eService Reviewed By: Adrienne Rocha
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.

Melody Agrait on behalf of Melanie Rubinsky
Bar No. 50511615
magrait@sprottnewsom.com
Envelope ID: 62422320
Status as of 3/9/2022 8:07 AM CST

Case Contacts

Juan JHinojosa JJHinojosa@Bizrgv.rr.com 3/8/2022 5:02:28 PM SENT

Rose Marshall rmarshall@seyfarth.com 3/8/2022 5:02:28 PM SENT

Hector LRodriguez Hectorlawfirm@gmail.com 3/8/2022 5:02:28 PM SENT

Ezequiel Moya emoya@valleyfirm.com 3/8/2022 5:02:28 PM SENT

Martin J.Phipps Mphipps@phippsandersondeacon.com 3/8/2022 5:02:28 PM SENT

Steven Engelhardt steven@engelhardtlaw.com 3/8/2022 5:02:28 PM SENT

Steven M.Gonzalez sgonzalez@valleyfirm.com 3/8/2022 5:02:28 PM SENT

Neisha RiceAndres nandres@seyfarth.com 3/8/2022 5:02:28 PM SENT

Anthony "Tony"James ajames@hodgejames.com 3/8/2022 5:02:28 PM SENT

Edward J.Castillo ecastillo@valleyfirm.com 3/8/2022 5:02:28 PM SENT

Patricia McCulloch pmcculloch@tureklawfirm.com 3/8/2022 5:02:28 PM SENT

B. ClaytonHackett chackett@valdeztrevino.com 3/8/2022 5:02:28 PM ERROR

Robert E.Valdez jtrevino@valdeztrevino.com 3/8/2022 5:02:28 PM SENT

Melody Agrait magrait@sprottnewsom.com 3/8/2022 5:02:28 PM SENT

Steven M.Vidaurri svidaurri@vlrhlaw.com 3/8/2022 5:02:28 PM SENT

Jorge Green jorge@thegreenlawfirm.com 3/8/2022 5:02:28 PM SENT

Gerald E.Castillo gcastillo@valleyfirm.com 3/8/2022 5:02:28 PM ERROR

Rose Vela rose.vela@me.com 3/8/2022 5:02:28 PM SENT

Leticia Garza Lety@thegreenlawfirm.com 3/8/2022 5:02:28 PM SENT

Jorge A.Green Jorge@thegreenlawfirm.com 3/8/2022 5:02:28 PM SENT

Soledad McLain SMclain@thegreenlawfirm.com 3/8/2022 5:02:28 PM SENT

Vanessa Serna VSerna@thegreenlawfirm.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: McAllen Medical Center, Inc.
Electronically Filed
7/25/2022 1:56 PM
Hidalgo County District Clerks
Automated Certificate of eService Reviewed By: Adrienne Rocha
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.

Melody Agrait on behalf of Melanie Rubinsky
Bar No. 50511615
magrait@sprottnewsom.com
Envelope ID: 62422320
Status as of 3/9/2022 8:07 AM CST

Associated Case Party: McAllen Medical Center, Inc.

Name BarNumber Email TimestampSubmitted Status

David GOliveira doliveira@rofllp.com 3/8/2022 5:02:28 PM SENT

Liz Alvarado lizg@rofllp.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: ROUND TABLE PHYSICIANS GROUP, PLLC

Name BarNumber Email TimestampSubmitted Status

Melanie Rubinsky mrubinsky@sprottnewsom.com 3/8/2022 5:02:28 PM SENT

Kay Hazelwood Khazelwood@Seyfarth.com 3/8/2022 5:02:28 PM SENT

Andrew P.del Junco adeljunco@seyfarth.com 3/8/2022 5:02:28 PM SENT

Jacquelyn Stephenson JStephenson@seyfarth.com 3/8/2022 5:02:28 PM SENT

Roger Donnellan rdonnellan@seyfarth.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Rio Grande Regional Hospital, Inc.

Name BarNumber Email TimestampSubmitted Status

Sofia Amabel Ramon 784811 efile@ramonworthington.com 3/8/2022 5:02:28 PM SENT

Daniel Keith Worthington 785282 dworthington@ramonworthington.com 3/8/2022 5:02:28 PM SENT

Richard B.Phillips, Jr. richard.phillips@hklaw.com 3/8/2022 5:02:28 PM SENT

Associated Case Party: Resource Corporation of America & Recovery of Texas,
L.L.C.

Name BarNumber Email TimestampSubmitted Status

Lawrence Rothenberg rothenber2@gmail.com 3/8/2022 5:02:28 PM SENT

James Mcgregor jmcgregor@wmbwaco.com 3/8/2022 5:02:28 PM SENT

Case Info

Judge

Ysmael D. Fonseca Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

July 25, 2022

Case Filing Date

June 07, 2019

County

Parties

JAMES MICHAEL MOORE Attorney for the Plaintiff
MELAINE A. RUBINSKY Attorney for the Defendant
PEREZ, EDGAR Plaintiff
Round Table Physicians Group, PLLC Defendant
SIGNATURE CARE EMERGENCY CENTER Defendant
Joel Mohrman Attorney
Anderson Cao Attorney
David Oliveira Attorneys for Defendants
Juan Hinojosa Attorneys for Defendants
Kay Hazelwood Attorneys for Defendants
Christopher Demeo Attorneys for Defendants
Andrew del Junco Attorneys for Defendants
Randolph Amaro Attorneys for Plaintiffs

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Motion,Ex Parte: EDGAR PEREZ vs. SIGNATURE CARE EMERGENCY CENTER,Round Table Physicians Group, PLLC

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