Answer: PREXUS HEALTH CONSULTANTS LLC vs. UNIVERSITY GENERAL HOSPITAL SYSTEMS LLP (FKA UNIVE

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                                Filed 11 February 23 A11:51
                                                                                            Chris Daniel - District Clerk
                                                                                            Harris Coun!
                                                                                            ED101) 016191022
                                                                                            By: angellia Dozier
                                           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 FIRST AMENDED ANSWER

           Defendant Luxxus Health Systems, LLC ("Luxxus”) answers the claims and allegations

stated against it in the latest amended petition (the “Petition”) filed by Plaintiff Prexus Health

Consultants, LLC (“Prexus”).

                                            GENERAL DENIAL

           Luxxus asserts a general denial of the allegations presented by the Petition, as permitted

by Rule 92 of the Texas Rules of Civil Procedure, and demands strict proof of the allegations.

                                        AFFIRMATIVE DEFENSES

           1        Prexus’s   claims   fail because the statements alleged     did not occur,    are not

actionable, and, alternatively and upon information and belief, are true.

           2.       Prexus’s claims fail because it breached the contracts as to which it alleges

tortious interference on grounds unrelated to any conduct of this defendant.

           3        Prexus’s claims must be reduced by its avoided cost of performing the contracts

in question and its obligation to mitigate its damages.

           4        Certain of Prexus’s    claims   are subject to Texas’s    comparative   responsibility

statute.

           5        Any injuries or damages suffered by Prexus were not caused by this Defendant,