On March 19, 2021 a
Complaint,Petition
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
3/27/2024 5:32 PM
Hidalgo County District Clerks
Reviewed By: Priscilla Rivas
Adrian M. Lozano
www.khitchiropractic.com State Bar No. 24121571
Email: legal@khitchiropractic.com
March 27, 2024
Hidalgo County District Clerk
430th Judicial District Court
Via: E-file Texas
Re: Submission of Attachments for Plaintiffs’ Second Amended Verified Original
Petition in Cause No. C-1080-21-J:
Khit & Associates, PLLC d/b/a Khit Chiropractic & Wellness Center and Skak
Investments, LLC d/b/a Insight Diagnostics & Imaging Center, and Kay Medical
Center, PLLC v. Law Offices of Ezequiel Reyna, Jr., Ezequiel Reyna Jr., Ruiz Law
Center, PLLC, and Gustavo C. Ruiz.
Dear Clerk of the 430th Judicial District Court,
Please find enclosed herein the attachments related to Plaintiffs’ Second Amended Verified
Original Petition, which was filed on March 27, 2024, in the above-referenced case.
Due to the extensive nature and considerable volume of the supporting documents, the file
size exceeded the limitations for a single electronic filing. To ensure completeness and maintain
the integrity of the information presented, I have separated the documents into distinct parts. This
letter accompanies Exhibit B of the attachments.
These documents are incorporated by reference into Plaintiffs’ Second Amended Verified
Original Petition pursuant to Rule 185 of the Texas Rules of Civil Procedure.
Should there be any issues with the documents or if additional information is required,
please do not hesitate to contact me.
Thank you for your attention to this matter.
Sincerely,
__/s/ Adrian Lozano_______
Adrian M. Lozano
ATTORNEY FOR PLAINTIFFS
401 N. Bryan Rd., Mission, Texas 78572 â–ª t: 956-271-4771 â–ª f: 956-583-4433
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.
Adrian Lozano on behalf of Adrian Lozano
Bar No. 24121571
legal@khitmdgroup.com
Envelope ID: 86044866
Filing Code Description: Exhibit
Filing Description: B TO PLAINTIFFS’ SECOND AMENDED VERIFIED
ORIGINAL PETITION
Status as of 3/28/2024 9:48 AM CST
Associated Case Party: Khit & Associates, L.L.C. d/b/a Khit Chiropractic & Wellness
Centers
Name BarNumber Email TimestampSubmitted Status
LANCE KASSAB NICHOLAS@KASSAB.LAW 3/27/2024 5:32:38 PM SENT
Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C.
Name BarNumber Email TimestampSubmitted Status
MICAH DORTCH MDORTCH@POTTS-LAW.COM 3/27/2024 5:32:38 PM SENT
Associated Case Party: Ezequiel Reyna
Name BarNumber Email TimestampSubmitted Status
Raymond LThomas rthomas@raythomaspc.com 3/27/2024 5:32:38 PM SENT
LANCE KASSAB lance@kassab.law 3/27/2024 5:32:38 PM SENT
Associated Case Party: Ruiz Law Center, PLLC
Name BarNumber Email TimestampSubmitted Status
William L.Pope pope@adamsgraham.com 3/27/2024 5:32:38 PM SENT
Tristan Clark tclark@adamsgraham.com 3/27/2024 5:32:38 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 3/27/2024 5:32:38 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.
Adrian Lozano on behalf of Adrian Lozano
Bar No. 24121571
legal@khitmdgroup.com
Envelope ID: 86044866
Filing Code Description: Exhibit
Filing Description: B TO PLAINTIFFS’ SECOND AMENDED VERIFIED
ORIGINAL PETITION
Status as of 3/28/2024 9:48 AM CST
Case Contacts
LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 3/27/2024 5:32:38 PM SENT
Kimberlee Wagman kimwagman@adamsgraham.com 3/27/2024 5:32:38 PM SENT
ADRIAN LOZANO LEGAL@KHITMDGROUP.COM 3/27/2024 5:32:38 PM SENT
MICAH DORTCH DORTCH-MDORTCH@POTTS-LAW.COM 3/27/2024 5:32:38 PM ERROR
Document Filed Date
March 27, 2024
Case Filing Date
March 19, 2021
Category
Contract - Other Contract (OCA)
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Electronically Filed 3/27/2024 5:32 PM Hidalgo County District Clerks Reviewed By: Priscilla Rivas Adrian M. Lozano www.khitchiropractic.com State Bar No. 24121571 Email: legal@khitchiropractic.com March 27, 2024 Hidalgo County District Clerk 430th Judicial District Court Via: E-file Texas Re: Submission of Attachments for Plaintiffs’ Second Amended Verified Original Petition in Cause No. C-1080-21-J: Khit & Associates, PLLC d/b/a Khit Chiropractic & Wellness Center and Skak Investments, LLC d/b/a Insight Diagnostics & Imaging Center, and Kay Medical Center, PLLC v. Law Offices of Ezequiel Reyna, Jr., Ezequiel Reyna Jr., Ruiz Law Center, PLLC, and Gustavo C. Ruiz. Dear Clerk of the 430th Judicial District Court, Please find enclosed herein the attachments related to Plaintiffs’ Second Amended Verified Original Petition, which was filed on March 27, 2024, in the above-referenced case. Due to the extensive nature and considerable volume of the supporting documents, the file size exceeded the limitations for a single electronic filing. To ensure completeness and maintain the integrity of the information presented, I have separated the documents into distinct parts. This letter accompanies Exhibit B of the attachments. These documents are incorporated by reference into Plaintiffs’ Second Amended Verified Original Petition pursuant to Rule 185 of the Texas Rules of Civil Procedure. Should there be any issues with the documents or if additional information is required, please do not hesitate to contact me. Thank you for your attention to this matter. Sincerely, __/s/ Adrian Lozano_______ Adrian M. Lozano ATTORNEY FOR PLAINTIFFS 401 N. Bryan Rd., Mission, Texas 78572 ▪ t: 956-271-4771 ▪ f: 956-583-4433 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. Adrian Lozano on behalf of Adrian Lozano Bar No. 24121571 legal@khitmdgroup.com Envelope ID: 86044866 Filing Code Description: Exhibit Filing Description: B TO PLAINTIFFS’ SECOND AMENDED VERIFIED ORIGINAL PETITION Status as of 3/28/2024 9:48 AM CST Associated Case Party: Khit & Associates, L.L.C. d/b/a Khit Chiropractic & Wellness Centers Name BarNumber Email TimestampSubmitted Status LANCE KASSAB NICHOLAS@KASSAB.LAW 3/27/2024 5:32:38 PM SENT Associated Case Party: Law Offices of Ezequiel Reyna, Jr. P.C. Name BarNumber Email TimestampSubmitted Status MICAH DORTCH MDORTCH@POTTS-LAW.COM 3/27/2024 5:32:38 PM SENT Associated Case Party: Ezequiel Reyna Name BarNumber Email TimestampSubmitted Status Raymond LThomas rthomas@raythomaspc.com 3/27/2024 5:32:38 PM SENT LANCE KASSAB lance@kassab.law 3/27/2024 5:32:38 PM SENT Associated Case Party: Ruiz Law Center, PLLC Name BarNumber Email TimestampSubmitted Status William L.Pope pope@adamsgraham.com 3/27/2024 5:32:38 PM SENT Tristan Clark tclark@adamsgraham.com 3/27/2024 5:32:38 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 3/27/2024 5:32:38 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. Adrian Lozano on behalf of Adrian Lozano Bar No. 24121571 legal@khitmdgroup.com Envelope ID: 86044866 Filing Code Description: Exhibit Filing Description: B TO PLAINTIFFS’ SECOND AMENDED VERIFIED ORIGINAL PETITION Status as of 3/28/2024 9:48 AM CST Case Contacts LANCE CHRISTOPHERKASSAB LANCE@KASSAB.LAW 3/27/2024 5:32:38 PM SENT Kimberlee Wagman kimwagman@adamsgraham.com 3/27/2024 5:32:38 PM SENT ADRIAN LOZANO LEGAL@KHITMDGROUP.COM 3/27/2024 5:32:38 PM SENT MICAH DORTCH DORTCH-MDORTCH@POTTS-LAW.COM 3/27/2024 5:32:38 PM ERROR