Motion,Ex Parte: PREXUS HEALTH CONSULTANTS LLC vs. UNIVERSITY GENERAL HOSPITAL SYSTEMS LLP (FKA UNIVE

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                                Filed 11 March 3 P2:01
                                                                                                         Chris Daniel - District Clerk
                                                                                                         Harris Coun!
                                                                                                         ED101) 016203604
                                                                                                         By: Nelson Cuero
                                              Cause No. 2009-77474
PREXUS HEALTH CONSULTANTS, LLC                                          IN THE DISTRICT COURT OF

        Plaintiff,
Vv.
                                                                        HARRIS COUNTY, TEXAS
UNIVERSITY GENERAL HOSPITAL
SYSTEMS, LLP f/k/a UNIVERSITY
GENERAL HOSPITAL, L.P. and
ASCENSION PHYSICIAN SOLUTIONS, LLC

        Defendants.                                                     270 JUDICIAL DISTRICT

                     DEFENDANT LUXXUS HEALTH SYSTEMS, LLC’S AMENDED
      TRADITIONAL AND NO-EVIDENCE MOTIONS FOR SUMMARY JUDGMENT

TO THE HONORABLE COURT:

        Defendant Luxxus Health Systems, LLC (“Luxxus”) moves for summary judgment on

the claims asserted it by Plaintiffs Prexus Health Consultants, LLC                         (“Prexus”} and Prexus

Health, LLC      (“Prexus Health”) under Rules              166a and 166a(i) of the Texas Rules of Civil

Procedure.

                                                       INTRODUCTION

        Prexus sues Luxxus for its alleged interference with two agreements under which Prexus

undertook    to (but      did not)     perform   the    management     and     administrative    functions    of the

University General        Hospital,     and for allegedly      interfering with the non-solicitation          clauses

contained in those agreements. Prexus also sues Luxxus for allegedly interfering with various

employment agreements of former Prexus Health employess and a Prexus contract to provide

administrative       services   to    the   Humble      Surgical   Hospital,    and   for    allegedly    publishing

disparaging and defamatory statements regarding Prexus to Humble Surgical Hospital investors.

All of these claims fail as a matter of law and of no-evidence. Prexus Health appears to state the

same claims on the same basis; its claims fail on the same grounds.