On July 12, 2021 a
Answer
was filed
involving a dispute between
Seaspine Sales Llc,
and
Ethicus Hospital Dfw Llc,
Psn Affiliates, Llc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
12/10/2021 10:55 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
CAUSE NO. DC-21-08988
SEASPINE SALES LLC IN THE DISTRICT COURT
Plaintiff
v. 1167’" JUDICIAL DISTRICT
PSN AFFILIATES, LLC AND
ETHICUS HOSPITAL DFW LLC D/B/A
LEGENT ORTHOPEDIC HOSPITAL
F/D/B/A SAGECREST HOSPITAL
CARROLLTON
Defendants DALLAS COUNTY, TEXAS
DEFENDANTS’ FIRST AMENDED ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC
DlB/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL
CARROLLTON, Defendants herein, and file this First Amended Answer to Plaintist Original
Petition on file herein and would respectfully show the Court as follows:
I.
VERIFIED DENIALS
Defendants deny the allegations contained in Plaintiff's Original Petition, and pursuant to
Texas Rule of Civil Procedure 185, and state that said allegations therein are not just and true.
Il.
Defendant PSN Affiliates, LLC is not liable in the capacity sued.
Page l of3
III.
GENERAL DENIAL
Defendants deny each and every, all and singular, the allegations contained within
Plaintifl‘s Original Petition and demand strict proof thereof.
WHEREFORE, PREMISES CONSIDERED, Defendants PSN AFFILIATES, LLC
AND ET HICUS HOSPITAL DFW LLC D/B/A LEGEN’I‘ ORT‘HOPEDIC HOSPITAL
FIB/BIA SAGECREST HOSPITAL CARROLLTON pray that upon final hearing hereof,
Plaintiff take nothing by Plaintiff’s Original Petition, that Defendants go hence Without day, and
have and recover such other and further relief, at law and in equity, general and special, to which
Defendants may be shown justly entitled to receive.
Respectfully submitted,
LAW OFFICES OF M. DREW SIEGEL
/s/ M. Drew Siege]
By:
M. DREW SIEGEL
State Bar No. 18342150
12830 l-Iillcrest Rd., Ste. 231
Dallas, Texas 75230
972/982-0410
Fax: 972/960-1476
drewsiegelfiflaol .com
Attorney for Defendants
VERIFICATION
The undersigned states and verifies that the statements in paragraphs l and II of this
Amended Answer are true and correct.
Ryan King
Page 2 of3
SUBSCRIBED AND SWORN TO BEFORE ME by Ryan King, on this [D‘Iéday of December,
2021, to certify which witness my oficial hand and seal of office.
My Commission expires:
' '
No and for flé State of Texas
Jannller Diane Freeze
My Cammleslon Explroa
8I2712025
Nola ID
13078 658
CERTIFIC TE OF SERVICE
«
The undersigned certifies that a true and correct c0py of the foregoing Amended Answer
has been served upon opposing counsel in this cause in accordance with the Texas Rules of Civil
Procedure, this day of December, 2021.
/s/ M. Drew Siege]
M. DREW SEGEL
Page 3 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.
Drew Siegel on behalf of M Drew Siegel
Bar No. 18342150
drew@drewsiegellaw.com
Envelope ID: 59905982
Status as of 12/13/2021 7:47 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
MARK ABUKATY bukatyatty@aol.com 12/10/2021 10:55:25 AM SENT
Drew Siegel drewsiegel@aol.com 12/10/2021 10:55:25 AM SENT
Document Filed Date
December 10, 2021
Case Filing Date
July 12, 2021
Category
CNTR CNSMR COM DEBT
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Preview
FILED 12/10/2021 10:55 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY CAUSE NO. DC-21-08988 SEASPINE SALES LLC IN THE DISTRICT COURT Plaintiff v. 1167’" JUDICIAL DISTRICT PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC D/B/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL CARROLLTON Defendants DALLAS COUNTY, TEXAS DEFENDANTS’ FIRST AMENDED ANSWER TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC DlB/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL CARROLLTON, Defendants herein, and file this First Amended Answer to Plaintist Original Petition on file herein and would respectfully show the Court as follows: I. VERIFIED DENIALS Defendants deny the allegations contained in Plaintiff's Original Petition, and pursuant to Texas Rule of Civil Procedure 185, and state that said allegations therein are not just and true. Il. Defendant PSN Affiliates, LLC is not liable in the capacity sued. Page l of3 III. GENERAL DENIAL Defendants deny each and every, all and singular, the allegations contained within Plaintifl‘s Original Petition and demand strict proof thereof. WHEREFORE, PREMISES CONSIDERED, Defendants PSN AFFILIATES, LLC AND ET HICUS HOSPITAL DFW LLC D/B/A LEGEN’I‘ ORT‘HOPEDIC HOSPITAL FIB/BIA SAGECREST HOSPITAL CARROLLTON pray that upon final hearing hereof, Plaintiff take nothing by Plaintiff’s Original Petition, that Defendants go hence Without day, and have and recover such other and further relief, at law and in equity, general and special, to which Defendants may be shown justly entitled to receive. Respectfully submitted, LAW OFFICES OF M. DREW SIEGEL /s/ M. Drew Siege] By: M. DREW SIEGEL State Bar No. 18342150 12830 l-Iillcrest Rd., Ste. 231 Dallas, Texas 75230 972/982-0410 Fax: 972/960-1476 drewsiegelfiflaol .com Attorney for Defendants VERIFICATION The undersigned states and verifies that the statements in paragraphs l and II of this Amended Answer are true and correct. Ryan King Page 2 of3 SUBSCRIBED AND SWORN TO BEFORE ME by Ryan King, on this [D‘Iéday of December, 2021, to certify which witness my oficial hand and seal of office. My Commission expires: ' ' No and for flé State of Texas Jannller Diane Freeze My Cammleslon Explroa 8I2712025 Nola ID 13078 658 CERTIFIC TE OF SERVICE « The undersigned certifies that a true and correct c0py of the foregoing Amended Answer has been served upon opposing counsel in this cause in accordance with the Texas Rules of Civil Procedure, this day of December, 2021. /s/ M. Drew Siege] M. DREW SEGEL Page 3 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. Drew Siegel on behalf of M Drew Siegel Bar No. 18342150 drew@drewsiegellaw.com Envelope ID: 59905982 Status as of 12/13/2021 7:47 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status MARK ABUKATY bukatyatty@aol.com 12/10/2021 10:55:25 AM SENT Drew Siegel drewsiegel@aol.com 12/10/2021 10:55:25 AM SENT