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Filed 11 J anuary 21 P4:20
Chris Daniel - District Clerk
CAUSE NO. 2009-77474 Harris Coun!
ED101) 016145754
By: Wanda Chambers
PREXUS HEALTH CONSULTANTS, § IN THE DISTRICT COURT
LLC and PREXUS HEALTH, LLC,
Plaintiffs,
v. 270th SUDICTIAL DISTRICT
UNIVERSITY GENERAL HOSPITAL
SYSTEMS, LLP f/k/a UNIVERSITY
GENERAL HOSPITAL, LP,
ASCENSION PHYSICIAN SOLUTIONS,
LLC, DEVYN WOLENS,
INDIVIDUALLY, LUXXUS HEALTH
SYSTEMS, LLC, HASSAN CHADADEH.
INDIVIDUALLY, AND MIKE GRIFFIN,
INDIVIDUALLY,
Defendants. § HARRIS COUNTY, TEXAS
AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER
Plaintiffs Prexus Health Consultants, LLC and Prexus Health, LLC and
Defendants University General Hospital Systems, LLP f/k/a University General
Hospital,
LP, Ascension Physician Solutions, LLC, Devyn Wolens, Luxxus Health
Systems, LLC,
Hassan Chahadeh, and Mike Griffin (collectively, the “Parties”) file this Agreed
Motion
Sor Entry of Agreed Protective Order, and show the Court as follows:
1 The Parties desire to protect and prevent information, materials, and/or
documents produced in the above-referenced litigation that are claimed
and designated as
Confidential Information by a party, from disclosure or dissemination to persons and
entities other than Qualified Persons.
2 The Parties have agreed to a proposed Agreed Protective Order, a true and
correct copy of which is attached hereto as Exhibit “A” and incorporated herein.
AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER
61405_1.DOC Paget
WHEREFORE, PREMISES CONSIDERED, the Parties respectfully request the
Court to enter the attached proposed Agreed Protective Order.
Respectfully submitted,
GRUBER HURST JOHANSEN & HAIL, LLP
By Seals Ce
State Bar No. 10316310
Jonathan R. Childers
State Bar No, 24050411
1445 Ross Avenue, Suite 2500
Dallas, Texas 75202
(214) 855-6800 — phone
(214) 855-6808 — fax
ATTORNEYS FOR PLAINTIFFS PREXUS
HEALTH CONSULTANTS, LLC AND
PREXUS HEALTH, LLC
AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER Page 2
61405_1.DOC
AND
JOYCE, MCFARLAND + MCFARLAND LLP
By__ é
John H. McFarland
State Bar No, 00794270
Karen C, Brisch
State Bar No. 00790460
712 Main Street, Suite 1500
Houston, Texas 77002
(713) 229-1114
(713) 513-5577 (Pax)
ATTORNEYS FOR UNIVERSITY GENERAL
HOSPITAL SYSTEM, LLP f/k/a UNIVERSITY
GENERAL HOSPITAL, LP, ASCENSION
PHYSICIAN SOLUTIONS, LLC, LUXXUS
HEALTH SYSTEM, LLC, DR. HASSAN
CHAHADEH, INDIVIDUALLY, AND MIKE
GRIFFIN, INDIVIDUALLY
AND
STUART AND ASSOCIATES, PBC,
State Bar No, 00794705
Tonja K. King
State Bar No, 24040817
909 Fannin, Suite 3250
Houston, Texas 77010
(713) 337-3750
(713) 481-6320 (Pax)
ATTORNEYS FOR DEV¥YN WOLENS
AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER Page3
61403_Ldoc
CERTIFICATE OF CONFERENCE
The undersigned has conferred with counsel for Defendants Univers
ity General
Hospital Systems, LLP ffk/a University General Hospital, LP,
Ascension Physician
Solutions, LLC, Luxxus Health Systems, LLC, Hassan Chahadeh,
and Mike Griffin, and
also with counsel for Defendant Devyn Wolens, and said counsel
AGREE to the. relief
requested herein,
st
Certified to on this
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Filed 11 J anuary 21 P4:20 Chris Daniel - District Clerk CAUSE NO. 2009-77474 Harris Coun! ED101) 016145754 By: Wanda Chambers PREXUS HEALTH CONSULTANTS, § IN THE DISTRICT COURT LLC and PREXUS HEALTH, LLC, Plaintiffs, v. 270th SUDICTIAL DISTRICT UNIVERSITY GENERAL HOSPITAL SYSTEMS, LLP f/k/a UNIVERSITY GENERAL HOSPITAL, LP, ASCENSION PHYSICIAN SOLUTIONS, LLC, DEVYN WOLENS, INDIVIDUALLY, LUXXUS HEALTH SYSTEMS, LLC, HASSAN CHADADEH. INDIVIDUALLY, AND MIKE GRIFFIN, INDIVIDUALLY, Defendants. § HARRIS COUNTY, TEXAS AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER Plaintiffs Prexus Health Consultants, LLC and Prexus Health, LLC and Defendants University General Hospital Systems, LLP f/k/a University General Hospital, LP, Ascension Physician Solutions, LLC, Devyn Wolens, Luxxus Health Systems, LLC, Hassan Chahadeh, and Mike Griffin (collectively, the “Parties”) file this Agreed Motion Sor Entry of Agreed Protective Order, and show the Court as follows: 1 The Parties desire to protect and prevent information, materials, and/or documents produced in the above-referenced litigation that are claimed and designated as Confidential Information by a party, from disclosure or dissemination to persons and entities other than Qualified Persons. 2 The Parties have agreed to a proposed Agreed Protective Order, a true and correct copy of which is attached hereto as Exhibit “A” and incorporated herein. AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER 61405_1.DOC Paget WHEREFORE, PREMISES CONSIDERED, the Parties respectfully request the Court to enter the attached proposed Agreed Protective Order. Respectfully submitted, GRUBER HURST JOHANSEN & HAIL, LLP By Seals Ce State Bar No. 10316310 Jonathan R. Childers State Bar No, 24050411 1445 Ross Avenue, Suite 2500 Dallas, Texas 75202 (214) 855-6800 — phone (214) 855-6808 — fax ATTORNEYS FOR PLAINTIFFS PREXUS HEALTH CONSULTANTS, LLC AND PREXUS HEALTH, LLC AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER Page 2 61405_1.DOC AND JOYCE, MCFARLAND + MCFARLAND LLP By__ é John H. McFarland State Bar No, 00794270 Karen C, Brisch State Bar No. 00790460 712 Main Street, Suite 1500 Houston, Texas 77002 (713) 229-1114 (713) 513-5577 (Pax) ATTORNEYS FOR UNIVERSITY GENERAL HOSPITAL SYSTEM, LLP f/k/a UNIVERSITY GENERAL HOSPITAL, LP, ASCENSION PHYSICIAN SOLUTIONS, LLC, LUXXUS HEALTH SYSTEM, LLC, DR. HASSAN CHAHADEH, INDIVIDUALLY, AND MIKE GRIFFIN, INDIVIDUALLY AND STUART AND ASSOCIATES, PBC, State Bar No, 00794705 Tonja K. King State Bar No, 24040817 909 Fannin, Suite 3250 Houston, Texas 77010 (713) 337-3750 (713) 481-6320 (Pax) ATTORNEYS FOR DEV¥YN WOLENS AGREED MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER Page3 61403_Ldoc CERTIFICATE OF CONFERENCE The undersigned has conferred with counsel for Defendants Univers ity General Hospital Systems, LLP ffk/a University General Hospital, LP, Ascension Physician Solutions, LLC, Luxxus Health Systems, LLC, Hassan Chahadeh, and Mike Griffin, and also with counsel for Defendant Devyn Wolens, and said counsel AGREE to the. relief requested herein, st Certified to on this