Motion to Dismiss in JUANA LAGUNA, REGINO GONZALEZ, Sr., Joanna Gonzalez Acevedo VS. RAY FULP, III, DO, RAY FULP ORTHOPEDICS, PA, MARIA CAMACHO, MD, FRANCISCO TORRES, MD, ROBERT FOUNTILA, DO, RADIOLOGY & IMAGING OF SOUTH TEXAS, LLP, MCALLEN HOSPITALS, LP D/B/A MCALLEN MEDICAL CENTER| Trellis.Law

On March 05, 2013 a Motion,Ex Parte was filed involving a dispute between Acevedo, Joanna Gonzalez, Gonzalez, Regino, Sr., Laguna, Juana, and Camacho, Maria T., Md, Fountila, Robert C., Do, Fulp, Iii, Ray R., Do, Mcallen Hospitals, Lp D B A Mcallen Medical Center, Radiology & Imaging Of South Texas, Llp, Ray Fulp Orthopedics, Pa, Torres, Francisco, Md, for Injury or Damage - Medical Malpractice (OCA) in the District Court of Hidalgo County.

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CAUSE NO. C-0973-13-A

JUANA LAGUNA, JOANNA GONZALEZ § IN THE DISTRICT COURT
ADMINISTRATOR
ACEVEDO, AS OF THE §
ESTATE OF REGINO GONZALEZ, JR. §
§
v. § 92N° JUDICIAL DISTRICT
§
RAY R. FULP, Ill, D.O. RAY FULP §
ORTHOPEDICS, P.A., ROBERT C. §
FOUNTILA, D.O., McALLEN HOSPITALS, §
L.P., McALLEN MEDICAL CENTER, SOUTH §
TEXAS HEALTH SYSTEM, MCALLEN §
MEDICAL CENTER, INC. § HIDALGO COUNTY, TEXAS

DEFENDANTS McALLEN HOSPITALS, L.P., McALLEN MEDICAL CENTER,
SOUTH TEXAS HEALTH SYSTEM and McALLEN MEDICAL CENTER'SDISMISS
MOTION TO PURSUANT TO SECTION 7 4.351(b)

To the Honorable Luis M. Singleterry:

Defendants, McAllen Hospitals, LP; McAllen Medical Center; South Texas Health System;

and McAllen Medical Center, Inc. (collectively "hospital"), file this Motion to Dismiss pursuant

to TEX. CIV. PRAC. & REM. CODE § 7 4.351.

Statement of the Case

1. Plaintiff, Juana Laguna, individually and as next friend of Regina Gonzalez, Jr., a minor

child, and Plaintiff, Regina Gonzalez, Sr. ("Plaintiffs"), filed this action initially against the

hospital and several medical doctors to recover damages allegedly sustained as the result of

medical malpractice. Plaintiffs filed their original petition on March 5, 2013. Plaintiffs claim

generally that the hospital and the doctors were negligent and failed to use ordinary care in the

care and treatment of the minor child after he suffered a broken leg in December 2010. The

hospital filed an answer to the original petition on April 2, 2013. Plaintiffs did not file an expert
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report as to the hospital as of July 3, 2018, which is 120 days after Plaintiffs filed their original

petition.

2. Plaintiffs filed their first amended petition on September 24, 2013. The first

amended petition made several significant changes for purposes of this motion. First, the first

amended petition dropped Regino Gonzalez, Sr. as a plaintiff. Second, Plaintiff Regino Gonzalez,

Jr. ("Regino") had reached the age of majority at thetimethat Plaintiffs filed their first amended

petition, so he was proceeding on his own behalf. (/d.)("Regino Gonzalez, Jr., having reached the

age of majority, appearing on his own rights"). Finally, Plaintiffs dismissed the hospital from the

case by not naming the hospital as a Defendant in the introduction, the list of Defendants or

the allegations. (/d.).

3. Plaintiffs filed their second amended petition on December 14, 2018. By that

time, Regino had died from cancer. (/d. at 5.04). As a result, Plaintiffs included Juana Laguna,

as mother and heir ofthe estate, and Joann Gonzalez Acevedo, as Administrator and heir of the

estate. Plaintiffs named the hospital again as a Defendant in the case after having dismissed

the hospital in the first amended petition over five years earlier. In the second amended

petition, Plaintiffs claim that the hospital committed medical malpractice, and negligently

credentialed Ray R. Fulp, Ill,DO, who has been a Defendant in the case since Plaintiffs filed

their original petition.

4. Plaintiffs never served an expert report on the hospital at any time. The hospital

files this motion to dismiss based on Plaintiffs' failure to do so. The sanction is mandatory.

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Statement of Facts

5. Regino was born on June 19, 1995. According to Plaintiffs' Second Amended

Petition, he presented at the hospital on December 23, 2010 with a fracture of the left femur

in his leg that occurred spontaneously while he was engaged in routine activity. (/d.). Apparently,

a spontaneous fracture is a sign of a particular form of bone cancer. (/d.). Dr. Fulp and

Defendant, Robert Fountila, D.O., treated the child when he presented at the hospital. (/d.).

During surgery, on the leg, Dr. Fulp inserted a rod to help treat the fracture. Plaintiffs claim that

the doctors failed to diagnose the bone cancer. The child was last treated at the hospital on

January 31, 2011, when Dr. Fulp performed a biopsy.

6. Plaintiffs claim that the failure to diagnosis the bone cancer and the placement

of the rod in Regino's left femur caused the cancer to spread in his leg resulting in the

amputation of his leg. Unfortunately, the bone cancer spread to other parts of Regino's body,

and Regino died from the cancer on March 25, 2017. Plaintiffs then filed the original petition

on March 5, 2013.

Argument

7. The legislature passed the Medical Liability and Insurance Improvement Act,

Texas Civil Statutes Annotated Article 4590i (repealed) in 1977, to address a perceived problem

that patients werefilingfrivolous claims against health care providers that were not investigated

in a timely manner. Acts 1977, 65th Leg., Ch. 817, Part 1; House Committee on Civil Practices,

Bill Analysis, H.B. 971, 74th Legislature (1995); Tesch v. Stroud, 28 S.W.3d 782 (Tex. App.-

Corpus Christi 2000, pet. denied); Wood v. Tice, 988 S.W.2d 829 (Tex. App. - San Antonio

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1999, pet. denied); Clark v. HCA, Inc., 210 S.W.3d 1 (Tex. App. - El Paso 2005, no pet.). The

legislature believed that doctors and hospitals were forced to settle such claims, regardless of

the merits, or incur substantial and unnecessary costs to defend them, which increased the cost

and availability of health care in Texas. (/d.).

8. The legislature amended the Act in 1995 to include the expert report requirement

at issue in this motion. Act 1995, 74th Leg., Ch. 140, § 1. That amendment required a plaintiff

to provide each health care defendant with one or more expert reports relating to liability and

causation. Tesch, 28 S.W.3d at 784; Wood, 988 S.W.2d at 830. "Knowing what specific

conductthe Plaintiff's experts have called into question is critical to both the Defendant's ability

to prepare for trial and the trial court's ability to evaluate the viability of the plaintiff's claims."

American Transitional Care Centers of Texas v.Palacios, 46 S.W.3d 873, 877 (Tex. 2001);

Bowie Memorial Hospital v. Wright, 79 S.W.3d 48 (Tex. 2002). The legislature must have felt

that requiring a plaintiff to provide an expert report early in the case is "an obvious place to start

in attempting to reduce frivolous lawsuits." (/d.).

9. The legislature amended the Act again in 2003. Acts 2003, 78th Leg., Ch. 204,

§ 10.01. That amendment repealed Article 4590i but included many provisions of the former

law in Chapter 74 of the Texas Civil Practice and Remedies Code. The new statute included

several changes to the section on expert reports, which is now codified at Section 7 4.351.

Under the 2003 version of the Act, plaintiff had to serve an expert report that complied with the

statute within 120 days after filing the claim. If plaintiff did not serve the expert report within

the statutory deadline, the court, on the motion of the defendant health care provider, had to

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dismiss the case with prejudice, and award reasonable attorney's fees and costs of courtto the

defendant. Sections 74.351(b)(1), (2); Parker v. Simmons, 248 S.W.3d 860 (Tex. App. —

Texarkana 2008, no pet). The expert report must provide a fair summary ofthe opinions of the

expert about the applicable standard 0f care, the manner in which the health care provider

failed to meetthat standard, and any ca usal relationship between that failure and the damages

claimed in the case. Section 74.351(r)(6); Palacios, 46 S.W.3d at 877.

10. The 2003 version of the Act applies t0 this case because Plaintiffs filed their

original petition 0n March 5, 2013. Lateramendments in 2018 onlyapplyto health care liability

claims filed on or after September 1, 2013. Acts 2013, 83rd Leg., Ch. 870, §§ 3(b), (4)

(effective date 0f 2013 amendments); see Zanchr' v. Lane, 408 S.W.3d 373, 379 n. 2 (Tex.

2013). Thus, under the express terms of the statute, Plaintiffs had t0 file an expert report as to

the hospital no later than July 3, 2013. They failed to do so. As a result, the hospital is entitled

to a dismissal of Plaintiffs Claims with prejudice, and a recovery 0f attorney's fees and costs in

the case?

The Court should dismiss Plaintiffs’ claims because they did not comply with
Section 74.351.

11. Section 74.351(b) isclearand specific: ifPlaintiffs failed t0 serve an expert report

on the hospital timely that complies with Section 74.351(a), the Court “Shall” dismiss the case

1
The 2013 amendments to the statute require Plaintiffs to serve the expert report 120 days
after adefendant filed its answer in the case, ratherthan the date Plaintiffs filed their original petition.

Section 74.351; Acts 2013, 83rd Leg, Ch. 870 § 2. The hospital filed its answer on April 2, 2013. As
a result,the expert report would have been due on July 31, 2013. Plaintiffs did not file an expert report
by that date either, so whetherthe 2003 or2013 version 0f the Act applies to this case does not matter.

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against the hospital with prejudice and award costs and attorneys’ fees. The sanction is

mandatory. Section 74.351(b); Garcia v. Gomez, 319 S.W.3d 638, 640 (Tex. 2010)(“If no report

istimely served, the trial court must, on motion, dismiss the case.”); Parker v. Simmons, supra.

12. Plaintiffs alleged a health care liability claim against the hospital. In their

original petition, Plaintiffs claimed that the hospital was “negligent and failed to use ordinary

care” in Regino’s care and treatment. That allegation is the Standard and accepted definition

0f a health care liability claim. Pattern Jury Charge: Malpractice 50.2 (2018); Section

74.001(13)(definition of health care liability claim). There can be no dispute that Plaintiffs

alleged a Claim against the hospital subject t0 Section 74.351?

13. Plaintiffs failed to serve an expert report on the hospital timely under Section

74.351. As explained above, Plaintiff had to serve the report on the hospital 120 days after

they filed their original petition. They failed to d0 so. Even ifthe 2013 version of the statute

applies, which it does not, they would have had to serve the expert report within 120 days 0f

the date the hospital filed itsanswer which would have been July 31, 2013. They failed to do

so even though the case was stillpending against the hospital on that date.

14. The deadline to serve the expert report was not tolled. Plaintiffs filed their first

amended petition on September 24, 2013. In that petition, they dismissed the hospital by

2
In theirsecond amended petition, Plaintiffs added a claim for negligent credentialing of Dr.

Fulp against the hospital inaddition to medical malpractice. (Id.at 8.01, 8.02). Negligent credentialing
isa direct liabilityclaim against the hospital subject to Section 74.351. Tenet Health v. Zamora, 13
S.W.3d 464 (Tex. App. ~ Corpus Christi 2000, pet. dism'd); Danton Regional Medical Center v. LaCrofx,
947 S.W.2d 941 (Tex. App. — Fort Worth 1997, pet. denied); see generally Perdue, Direct Corporate
Liability of Hospitals, 24 S. Tex. L.J. 773 (1983).
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dropping the hospital from the pleading. An amendment of the pleading dismisses a party just

as effectively as if the court enters an order of dismissal. Thus, the hospital became "a stranger

to the litigation" as of the date the Plaintiffs filed their first amended petition. State v. Roberson,

409 S.W.2d 872 (Tex. Civ. App.- Tyler 1966, no writ); Chamberlain v. McReight, 713 S.W.2d

372 (Tex. App. - Beaumont 1986, writ ref'd n.r.e.). By the time Plaintiffs filed their first

amended petition and dismissed the claims against the hospital, their deadline to serve the

expert report had expired under either the 2003 or 2013 version of the statute.

15. Plaintiffs' dismissal of the health care liability claim against the hospital in 2013

did not give them a new deadline to serve expert reports when they named the hospital again

in December 2018. The courts have unanimously held that a plaintiff does not get an

additional120 days to file an expert report when the plaintiff files a second suit after dismissing

a first suit. The Court discussed this issue at length in Mokkala v.Mead, 178 S.W.3d 66 (Tex.

App. - Houston [14th Dist.] 2005, pet. denied). The Court concluded that a plaintiff could not

avoid a dismissal by a non-suit and refilingaftera careful analysis ofthe statutory language and

purpose. Other courts have agreed. Methodist Charlton Medical Center v. Steele, 27 4 S.W.3d

47 (Tex. App. - Dallas 2009, pet. denied)(failure to serve expert report within 120 days of

original petition required dismissal of the case even though claims were added after the

deadline expired); Runcie v. Foley, 27 4 S.W.3d 232 (Tex. App. - Houston [1st Dist.] 2008, no

pet.)(statutory period to file expert report began when plaintiff filed original action not when

plaintiff re-filed action after non-suit); Maxwell v. Siefert, 237 S.W.3d 423 (Tex. App.- Houston

[14th Dist.]2007, pet. denied)(all expert reports, including reports relevant to amended claims,

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must be served within 120 days of the date the original petition is filed); White v. Baylor All

Saints Medical Center, 2009 WL 1361612 *1 (Tex. App. -Amarillo 2009, pet. denied)("Every

opinion we found" holds that 120-day period does not begin anew when plaintiffs non-suit and

refile a health care liability claim).

16. The opinion ofthe Court in CHCA Woman's Hospital v. Lidji, 403 S.W.3d 228 (Tex.

2013) also supports this conclusion. In that case, plaintiffs dismissed their claims against the

hospita1116 days after filing their original petition. About two years later, plaintiffs filed a new

lawsuit against the hospital and served an expert report on the same day. The hospital claimed

that the report was not timely, and moved to dismiss the case under Section 7 4.351. The trial

court denied the motion, and the Court of Appeals affirmed.

17. The Supreme Court affirmed the judgment of the Court of Appeals. The Court's

reasoning is instructive here. The Court agreed that a claimant's non-suit and subsequent

refiling of a petition asserting a health care liability claim did not re-start the 120-day period to

serve the expert report. (/d. at 232), citing Runcie v. Foley, 274 S.W.3d 232 (Tex. App. -

Houston [1st Dist.]2008, no pet.); Mokkala v. Mead, 178 S.W.3d 66 (Tex. App.- Houston [14th

Dist.] 2005, pet denied). Instead, the Court held that the dismissal simply tolled the deadline

to serve the expert report until a claimant refiled the case. As a result, in that case, plaintiffs still

had four days before the deadline expired.

18. Here, the 120 days expired before Plaintiffs even dismissed the hospital from the

case. Thus, there was no additional time left for Plaintiffs to serve the expert report. As a result,

dismissal is proper against the hospital. Mokkala, supra at 68 n. 3 (court notes that the 120-day

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period had expired before the claimant took the non-suit). Plaintiffs have still not served an

expert report so any tolling provision would not help them anyway.

19. Plaintiffs also had to serve the expert report before the deadline even though

Regino was a minor when the initial lawsuit was filed. Plaintiffs' claims are derivative.

Juana Laguna brought the action in the original petition both individually and on behalf of

Regino who was a minor at the time. The 120-day period began to run as to all Plaintiffs who

were asserting a claim based on Regino's medical treatment when they filed the original

petition. Section 7 4.001(13) ("health care liability claim is a cause of action based on injury to

or death of a "claimant."); Section 7 4.001(2)("Ciaimant" includes any person seeking

damages).

20. The Court reached this issue in a similar context in lntracare Hospital North v.

Campbell, 222 S.W.3d 790 (Tex. App. - Houston [1st Dist.] 2007, no pet.). There, Cindy

Campbell brought a health care liability claim against the hospital as next friend of her adult

son, Frank Brown. She was later appointed his guardian. She served her expert report more

than 120 days after she filed the original petition but fewer than 120 days after she amended

the petition to reflect her status as Brown's guardian. The hospital filed a motion to dismiss. The

trial court denied the motion in relevant part, agreeing with Plaintiff that Brown's claims were

not before the court until she was appointed guardian.

21. The Court of Appeals reversed. The Court reasoned that the real party plaintiff in

a lawsuit asserted by a next friend or guardian is the incompetent person. (ld. at 796), citing

Garcia v. RC Cola-7-Up Bottling Co., 667 S.W.2d 517 (Tex. 1984); Wimberly v. Parish, 381

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S.W.2d 135 (Tex. Civ. App. - Beaumont 1964, writ ref'd n.r.e.). "When Campbell asserted

claims on behalf of Brown -whether mistakenly as his next friend or later and correctly as his

guardian -Brown was the real party plaintiff." (/d.) The Court concluded that: "Brown has been

at all times the true claimant under Section 7 4.351" so the deadline did not change based on

Campbell's capacity.

22. The same reasoning applies here. Whether Juana Laguna filed a claim as next

friend of Regina, or Regino filed a claim on his own behalf, Plaintiffs filed a claim for Regino's

death and Regino was the "claimant" in the case under the statute. Juana Laguna and

Joanna Acevedo "would have had the same powers and would have attempted to represent the

same person on the same claims." (/d. at 798). The legislative purpose would be thwarted

otherwise because the deadline could then be "greatly expanded." (/d. at 797). See also White

v. Baylor All Saints Medical Center, supra at *2 (rejecting the argument that the addition of new

claims starts the 120- day period over because the claims "encompass the same actors and

the same purportedly underlying cause of Warren's death.").

23. Finally, Regino's death does not restart the time to submit the expert report. By

statute, the deadline is measured from the date Plaintiffs filed their original petition. The statute

does not provide a different rule depending on the nature of Plaintiffs' damages. The statute

provides simply that: "In a health care liability claim, a claimant shall, not later than the 120th

day after the date the original petition was filed, serve on each party or the party's attorney one

or more expert reports."

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24. The reasoning of the cases on capacity applies equally well. Regina was the

claimant under the statute when he was a minor, when he sued on his own behalf, and after

he died. The claim always involved the same conduct, the same treatments, and the same

person. Plaintiffs' health care liability claims against the hospital remained the same, that is,

that the hospital breached the standard of care when Regina was treated at the hospital. The

deadline does not depend on the capacity ofthe person named in the petition or the damages

suffered.

25. The Court should focus on the essence of Plaintiffs' claim and consider the

alleged wrongful conduct and the duties allegedly breached rather than the injuries the

Plaintiffs suffered. Cardwell v. McDonald, 356 S.W.3d 646 (Tex. App. -Austin 2011, no pet.);

Diversicare General Partner v. Rubio, 185 S.W.3d 842 (Tex. 2005). The purpose of the statute

is to rule out frivolous lawsuits at the onset ofthe litigation before the parties have conducted

full discovery. Puppala v. Perry, 564 S.W.3d 190 (Tex. App.- Houston [1st Dist.]2018, no pet.);

Ross v. St. Luke's Episcopal Hospital, 462 S.W.3d 496 (Tex. 2015). Stated another way, the

purpose ofthe statute is to inform the defendant of the specific conduct the plaintiff has called

into question and to provide a basis for the trial court to conclude that the claims have merit.

Bowie Memorial Hospital v. Wright, 79 S.W.3d 48 (Tex. 2002); American Transitional Care

Centers v. Palacios, 46 S.W.3d 873 (Tex. 2001); Columbian North Hills Hospital Subsidiary v.

Alvarez, 382 S.W.3d 619 (Tex. App. -Fort Worth 2012, no pet.). That purpose depends on the

treatment or conduct by a health care provider, not the alleged damages suffered by the

patient.

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26. The purpose of the expert report would be defeated if a deadline to file the expert

report depended on the date a plaintiff suffers a particular injury or death rather than the date

plaintiff filed the original petition. Maxwell v.Seifert, 237 S.W.3d 423 (Tex. App. - Houston

[14th Dist.]2007, pet. denied); see Medical Hospital of Buna Texas v.Wheatley, 287 S.W.3d

286 (Tex. App. - Beaumont 2009, pet. denied)(amended petition that attempted to replead a

claim of simple negligence rather than a health care liability claim did not allow a new deadline

for the submission of expert reports). That same reasoning applies when a patient dies. The

statute is clear: the expert report must be served within 120 days of the date Plaintiffs filed

their original petition. The statute has no exception. The legislature could have provided an

exception but it did not. See lntracare Hospital North v. Campbell, supra (purpose of Section

74.351 is to give "hard and fast deadlines for the service of expert reports").

27. Plaintiffs did not serve an expert report as to the hospital required by

Section 7 4.351 within 120 days after they filed their original petition complaining about

Regina's medical treatment. The deadline passed whether it runs from the date that Plaintiffs

filed the original petition or the date that the hospital filed its answer. The statute requires the

Court to dismissthecaseagainstthe hospital. Section 74.351(b); Garcia v. Gomez, 319S.W.3d

638 (Tex. 2010). Frezza v. Flores,-- S.W.3d- -, 2018 WL 6069867 (Tex. App. -San Antonio

2018, no pet. hist.).

Conclusion

This Court should grant this motion to dismiss and dismiss all claims againstthe hospital

with prejudice. The Court should also award the hospital its attorney's fees and costs.

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By:

terWﬂzalez
SBN'. 0813 00
Edward J. Castillo

SBN: 24040658
Eduardo Moya
SBN: 24105674

1317 E. Quebec Avenue
McAllen, Texas 78503
(956) 618—0115
FAX: (956) 618-0445
Email: law@va||evfirm.com

ATTORNEYS FOR DEFENDANTS,
MCALLEN HOSPITALS, L.P. D/B/A MCALLEN MEDICAL
CENTER, SOUTH TEXAS HEALTH SYSTEM, and MCALLEN
MEDICAL CENTER, INC.

CERTIFICATE 0F SERVICE

l hereby certify that a true and correct copy of the above and foregoing document has
been forwarded t0 attorney for Plaintiffs Via fied mail, rn
_r_-.- receipt requested, and t0 all

other counsel of record via regular mail, on thi Iir-‘June, 2019.
II

F:\Data\data\WPDOCS\G\GonzaIez. MMC 21.165\mtd-03112019.km.wp
R. v.

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Case Info

Judge

Singleterry, Luis M. Party(LAGUNA, JUANA; GONZALEZ, REGINO, Jr. Track Judge’s New Case

Case No.

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Document Filed Date

June 07, 2019

Case Filing Date

March 05, 2013

County

Parties

Acevedo, Joanna Gonzalez Plaintiff
CAMACHO, MARIA T., MD Defendant
Edward J. Castillo Attorney for the Defendant
FOUNTILA, ROBERT C., DO Defendant
FULP, III, RAY R., DO Defendant
GAULT, BILL Attorney for the Defendant
GONZALEZ, REGINO, Sr. Plaintiff
JERRY D. PATCHEN Attorney for the Plaintiff
LAGUNA, JUANA Plaintiff
MCALLEN HOSPITALS, LP D/B/A MCALLEN MEDICAL CENTER Defendant
RADIOLOGY & IMAGING OF SOUTH TEXAS, LLP Defendant
RAY FULP ORTHOPEDICS, PA Defendant
RONALD G. HOLE Attorney for the Defendant
STEVEN M. GONZALEZ Attorney for the Defendant
TORRES, FRANCISCO, MD Defendant
William Gault Attorney
Marco De Luna Attorneys for Defendants
Ida Garza Attorneys for Defendants
Eduardo Moya Attorneys for Defendants
Richard Woolsey Attorneys for Defendants
Stephen Howen Attorneys for Defendants
Ezequiel Moya Attorneys for Defendants

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Motion,Ex Parte: JUANA LAGUNA, REGINO GONZALEZ, Sr., Joanna Gonzalez Acevedo VS. RAY FULP, III, DO, RAY FULP ORTHOPEDICS, PA, MARIA CAMACHO, MD, FRANCISCO TORRES, MD, ROBERT FOUNTILA, DO, RADIOLOGY & IMAGING OF SOUTH TEXAS, LLP, MCALLEN HOSPITALS, LP D/B/A MCALLEN MEDICAL CENTER

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