On April 09, 2024 a
Party Notice
was filed
involving a dispute between
Montanez, Samuel,
and
Rodriguez Engineering Laboratories Llc,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
9/8/2023 10:02 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
C-1666-24-B
CAUSE NO. CL-23-1537-1
SAMUEL MONTANEZ § IN THE COUNTY COURT
§
§
VS. §
§ AT LAW NO. 9
§
RODRIGUEZ ENGINEERING §
LABORATORIES, LLC §
§ HIDALGO COUNTY, TEXAS
DEFENDANT RODRIGUEZ ENGINEERING LABORATORIES, LLC NOTICE OF FILING
CONTROVERTING AFFIDAVITS
TO: Samuel Montanez, by and through his Counsel of Record,
Raul Medina
3101 N Jackson Rd
McAllen, Texas 78501
NOTICE OF SERVICE OF COUNTERAFFIDAVIT
Pursuant to Section 18.001(e) of the Texas Civil Practice & Remedies Code,
RODRIGUEZ ENGINEERING LABORATORIES LLC (“Defendant”) hereby gives all
concerned parties in the above styled and numbered cause notice of filing with the Clerk of
the Court, the following counter affidavit to controvert medical billing records and charges
filed for services allegedly received by Plaintiff:
1) Counter-Affidavit of Emily Stablein, CPC-A, Concerning Cost of Medical
Services Regarding Samuel Montanez.
You are further hereby notified that the above-described counter affidavit may be
used by Defendant as evidence in any proceeding or trial of this case. A true and correct
copy of the original affidavit is attached hereto as Exhibit 1 and is hereby being filed with
66155:47257817
Electronically Submitted
9/8/2023 10:02 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
the Clerk of the Court. This notice and the attached affidavit are being forwarded to counsel
for Plaintiff and all other parties of record in this cause via their counsel.
II.
NO ADMISSION THAT PLAINTIFF’S AFFIDAVITS ARE IN COMPLIANCE WITH
TEXAS CIVIL PRACTICE & REMEDIES CODE SECTION 18.001
By the filing of this Notice, Defendant, RODRIGUEZ ENGINEERING
LABORATORIES LLC, seeks to meet its own requirements under Texas Civil Practice and
Remedies Code Section 18.001. Defendant clarifies here that this Notice does not
constitute an admission that Plaintiff’s affidavits are properly served upon Defendant or that
Plaintiff’s affidavits are in accordance with the requirements of Texas Civil Practice and
Remedies Code Section 18.001. Defendant reserves the right to later file a Motion with this
Court to Strike Plaintiff’s initial affidavits for any deficiencies the affidavits may have under
the Texas Civil Practice and Remedies Code Section 18.001.
III.
WHEREFORE PREMISES CONSIDERED, Defendant gives notice of service to all
counsel of record, pursuant to Texas Civil Practice and Remedies Code Section 18.001,
the attached counter affidavit, the basis of which Defendant, RODRIGUEZ ENGINEERING
LABORATORIES LLC, intends to use at trial to controvert the claims reflected by the
Plaintiff’s initial affidavits.
Respectfully submitted,
ROYSTON, RAYZOR, VICKERY & WILLIAMS, LLP
By: /s/Maulik P. Shah____________
Maulik P. Shah
State Bar No. 24079306
maulik.shah@roystonlaw.com
66155:47257817
Electronically Submitted
9/8/2023 10:02 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
1415 Louisiana Street, Ste 4200
Houston, Texas 77002
Tel: (713) 224-8380
Fax: (713) 225-9945
-and-
Allison M. Koltunchik
State Bar No. 24131434
Allison.koltunchik@roystonlaw.com
55 Cove Circle
Brownsville, TX 78521
Tel: (956) 542-4377
Fax: (956) 542-4370
ATTORNEYS FOR DEFENDANT,
RODRIGUEZ ENGINEERING
LABORATORIES, LLC
66155:47257817
Electronically Submitted
9/8/2023 10:02 AM
Hidalgo County Clerk
Accepted by: Sarah Reyes
CERTIFICATE OF SERVICE
I hereby certify that on the 8th day of September 2023, a true and correct copy of the
foregoing has been served upon all counsel of record pursuant to TEX. R. CIV. P. 21a.
Raul Medina
3101 N Jackson Rd
McAllen, Texas 78501
Attorney for Plaintiff
/s/ Maulik P. Shah
Maulik P. Shah
66155:47257817
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.
Sonia Mata on behalf of Maulik Shah
Bar No. 24079306
sonia.mata@roystonlaw.com
Envelope ID: 79339817
Filing Code Description: Notice
Filing Description: Def's Notice of Filing Controverting Aff Samuel
Montanez
Status as of 9/8/2023 10:28 AM CST
Associated Case Party: Samuel Montanez
Name BarNumber Email TimestampSubmitted Status
Raul Medina raul@raulmedinalaw.com 9/8/2023 10:02:49 AM SENT
Associated Case Party: Rodriguez Engineering Laboratories LLC
Name BarNumber Email TimestampSubmitted Status
laura Sifuentes laura.sifuentes@roystonlaw.com 9/8/2023 10:02:49 AM SENT
Maulik P.Shah maulik.shah@roystonlaw.com 9/8/2023 10:02:49 AM SENT
Allison M. Koltunchik allison.koltunchik@roystonlaw.com 9/8/2023 10:02:49 AM SENT
Sonia Mata sonia.mata@roystonlaw.com 9/8/2023 10:02:49 AM SENT
Document Filed Date
April 09, 2024
Case Filing Date
April 09, 2024
Category
Injury or Damage - Motor Vehicle (OCA)
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Preview
Electronically Submitted 9/8/2023 10:02 AM Hidalgo County Clerk Accepted by: Sarah Reyes C-1666-24-B CAUSE NO. CL-23-1537-1 SAMUEL MONTANEZ § IN THE COUNTY COURT § § VS. § § AT LAW NO. 9 § RODRIGUEZ ENGINEERING § LABORATORIES, LLC § § HIDALGO COUNTY, TEXAS DEFENDANT RODRIGUEZ ENGINEERING LABORATORIES, LLC NOTICE OF FILING CONTROVERTING AFFIDAVITS TO: Samuel Montanez, by and through his Counsel of Record, Raul Medina 3101 N Jackson Rd McAllen, Texas 78501 NOTICE OF SERVICE OF COUNTERAFFIDAVIT Pursuant to Section 18.001(e) of the Texas Civil Practice & Remedies Code, RODRIGUEZ ENGINEERING LABORATORIES LLC (“Defendant”) hereby gives all concerned parties in the above styled and numbered cause notice of filing with the Clerk of the Court, the following counter affidavit to controvert medical billing records and charges filed for services allegedly received by Plaintiff: 1) Counter-Affidavit of Emily Stablein, CPC-A, Concerning Cost of Medical Services Regarding Samuel Montanez. You are further hereby notified that the above-described counter affidavit may be used by Defendant as evidence in any proceeding or trial of this case. A true and correct copy of the original affidavit is attached hereto as Exhibit 1 and is hereby being filed with 66155:47257817 Electronically Submitted 9/8/2023 10:02 AM Hidalgo County Clerk Accepted by: Sarah Reyes the Clerk of the Court. This notice and the attached affidavit are being forwarded to counsel for Plaintiff and all other parties of record in this cause via their counsel. II. NO ADMISSION THAT PLAINTIFF’S AFFIDAVITS ARE IN COMPLIANCE WITH TEXAS CIVIL PRACTICE & REMEDIES CODE SECTION 18.001 By the filing of this Notice, Defendant, RODRIGUEZ ENGINEERING LABORATORIES LLC, seeks to meet its own requirements under Texas Civil Practice and Remedies Code Section 18.001. Defendant clarifies here that this Notice does not constitute an admission that Plaintiff’s affidavits are properly served upon Defendant or that Plaintiff’s affidavits are in accordance with the requirements of Texas Civil Practice and Remedies Code Section 18.001. Defendant reserves the right to later file a Motion with this Court to Strike Plaintiff’s initial affidavits for any deficiencies the affidavits may have under the Texas Civil Practice and Remedies Code Section 18.001. III. WHEREFORE PREMISES CONSIDERED, Defendant gives notice of service to all counsel of record, pursuant to Texas Civil Practice and Remedies Code Section 18.001, the attached counter affidavit, the basis of which Defendant, RODRIGUEZ ENGINEERING LABORATORIES LLC, intends to use at trial to controvert the claims reflected by the Plaintiff’s initial affidavits. Respectfully submitted, ROYSTON, RAYZOR, VICKERY & WILLIAMS, LLP By: /s/Maulik P. Shah____________ Maulik P. Shah State Bar No. 24079306 maulik.shah@roystonlaw.com 66155:47257817 Electronically Submitted 9/8/2023 10:02 AM Hidalgo County Clerk Accepted by: Sarah Reyes 1415 Louisiana Street, Ste 4200 Houston, Texas 77002 Tel: (713) 224-8380 Fax: (713) 225-9945 -and- Allison M. Koltunchik State Bar No. 24131434 Allison.koltunchik@roystonlaw.com 55 Cove Circle Brownsville, TX 78521 Tel: (956) 542-4377 Fax: (956) 542-4370 ATTORNEYS FOR DEFENDANT, RODRIGUEZ ENGINEERING LABORATORIES, LLC 66155:47257817 Electronically Submitted 9/8/2023 10:02 AM Hidalgo County Clerk Accepted by: Sarah Reyes CERTIFICATE OF SERVICE I hereby certify that on the 8th day of September 2023, a true and correct copy of the foregoing has been served upon all counsel of record pursuant to TEX. R. CIV. P. 21a. Raul Medina 3101 N Jackson Rd McAllen, Texas 78501 Attorney for Plaintiff /s/ Maulik P. Shah Maulik P. Shah 66155:47257817 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. Sonia Mata on behalf of Maulik Shah Bar No. 24079306 sonia.mata@roystonlaw.com Envelope ID: 79339817 Filing Code Description: Notice Filing Description: Def's Notice of Filing Controverting Aff Samuel Montanez Status as of 9/8/2023 10:28 AM CST Associated Case Party: Samuel Montanez Name BarNumber Email TimestampSubmitted Status Raul Medina raul@raulmedinalaw.com 9/8/2023 10:02:49 AM SENT Associated Case Party: Rodriguez Engineering Laboratories LLC Name BarNumber Email TimestampSubmitted Status laura Sifuentes laura.sifuentes@roystonlaw.com 9/8/2023 10:02:49 AM SENT Maulik P.Shah maulik.shah@roystonlaw.com 9/8/2023 10:02:49 AM SENT Allison M. Koltunchik allison.koltunchik@roystonlaw.com 9/8/2023 10:02:49 AM SENT Sonia Mata sonia.mata@roystonlaw.com 9/8/2023 10:02:49 AM SENT