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

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                                Filed 11 J anuary 25 P5:37
                                                                                             Chris Daniel - District Clerk
                                                                                             Harris Coun!
                                                                                             ED101) 016150176
                                                                                             By: Sandra Talbert
                                       Cause No. 2009-77474
PREXUS HEALTH CONSULTANTS, LLC                                IN THE DISTRICT COURT OF

       Plaintiff,
Vv.
                                                              HARRIS COUNTY, TEXAS
UNIVERSITY GENERAL HOSPITAL
SYSTEMS, LLP ffk/a UNIVERSITY
GENERAL HOSPITAL, LP. and
ASCENSION PHYSICIAN SOLUTIONS, LLC

       Defendants.                                            270" JUDICIAL DISTRICT

               DEFENDANT LUXXUS HEALTH SYSTEMS, LLC’S 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. This claim fails as a matter of law and of no-evidence. Prexus

Health appears to state the same claim on the same basis. This claim fails on the same grounds.

                                  SUMMARY JUDGMENT EVIDENCE

       Luxxus attaches the following as summary judgment evidence:

       A. Affidavit of Kelly Riedel.

                    1   August   6, 2009   Notice   of Material   Breach   of Professional      Services
                        Agreement and Consulting Services Agreement.