Preview
3/9/2015 5:24:02 PM
Velva L. Price
District Clerk
Travis County
CAUSE NO. D-1-GN-14-005419 D-1-GN-14-005419
OPSMD, INC. § IN THE DISTRICT COURT
§
Plaintiff, §
§
vy. §
§ TRAVIS COUNTY, TEXAS
MEDIGAIN, LLC, GREG HACKNEY,
AND PRUDENTIAL INVESTMENTS = §
MANAGEMENT, INC. D/B/A §
PRUDENTIAL CAPITAL GROUP 8
§
Defendants. § 98" JUDICIAL DISTRICT
DEFENDANTS’ RESPONSES TO PLAINTIFF’S REQUEST FOR DISCLOSURES
To: Plaintiff OpsMD, Inc., by and through its attorney of record, J. David Rowe, Esq.,
DuBois, Bryant & Campbell, LLP, 700 Lavaca Street, Suite 1300, Austin, Texas 78701.
Comes now MediGain, LLC and Greg Hackney (“Defendants”) and serve their
Responses to Plaintiff's Request for Disclosures as follows:
Rule 194.2(a): the correct names of the parties to the lawsuit.
Response: The names of the parties are correct.
Rule 194.2(b): the name, address, and telephone number of any potential parties.
Response: April G. Arzate of OpsMD, Inc., 12741 Research Blvd., Suite 500, Austin,
Texas 78759.
Rule 194.2(c): the legal theories and, in general, the factual bases of the responding
party’s claims or defenses.
Response:
The legal theories and supporting facts are based upon information and documents that
are presently available to, and specifically known to, Defendants at this time, as well as
information and belief that Defendants expect to confirm through discovery. Defendants have
not fully completed their investigation of the facts relating to this case, have not completed
discovery in this action, and have not completed preparation for trial. It is anticipated that further
DEFENDANTS’ INITIAL DISCLOSURES PAGE 1discovery, independent investigation, legal research, and analyses will supply additional facts
and add meaning to known facts, which may lead to additions, changes, and variations to the
factual bases of Defendants’ legal defense theories.
The claims asserted by Plaintiff are without factual or legal merit. Defendants deny each
and every, all and singular, material allegation of Plaintiff's First Amended Petition.
Specifically, Defendants deny they are liable on the Promissory Note at issue (the
“Note”) because the Note lacked consideration and is therefore legally unenforceable.
Alternatively, Defendants deny they are liable on the Note because, on information and
belief, April G. Arzate committed a prior material breach of her non-competition agreement with
MediGain, LLC that absolved Defendants’ duty to continue performing under the Note.
Alternatively, Defendants deny they owe any additional payment under the Note because
they formed an agreement with Plaintiff and/or April G. Arzate that required Defendants to
provide OpsMD, Inc. d/b/a Ascend Health Services and/or April G. Arzate with equity in
MediGain, LLC in exchange for the remaining Note balance. The agreement eliminated any
further obligation to make Note payments. Multiple documented discussions evidence that this
agreement existed but was not finalized due to delay on Ms. Arzate’s part. Such discussions
include, but are not limited to, the following:
1. March 13, 2013, email communications between April G. Arzate, Greg Hackney,
Chief Executive Officer of MediGain, LLC, and Ray A. Balestri, counsel for
MediGain LLC, regarding (1) the official name in which to issue the MediGain, LLC
equity units, (2) complications with issuing the MediGain, LLC equity to Ms. Arzate
personally because the Note was made payable to OpsMD, Inc. d/b/a Ascend Health
Services, and (3) recommendation that Ms. Arzate dividend the Note to the OpsMD,
Inc. shareholders (exclusively Ms. Arzate) so she could convert the Note personally
into MediGain, LLC equity units.
2. December 17, 2013, email communications between April G. Arzate, Bryan Lee,
counsel for Ms. Arzate, and Ray A. Balestri regarding the tax implications for Ms.
Arzate for personal receipt of the MediGain, LLC equity.
3. A May 2, 2014, email communication between April G. Arzate, Bryan Lee, and Ray
A. Balestri in which Ms. Arzate wrote, “Bryan and I are back on track to get this
[equity transfer] completed, and after further discussion on the tax concems, we
wanted to request the subscription agreement be resent under OPSMD, Inc. dba
Ascend Health service. Also, we’d appreciate a copy of the capitalization table and
LLC Agreement.”
These emails indicate that Defendants and Plaintiff and/or April G. Arzate formed the
agreement to provide equity in MediGain, LLC in exchange for the total amount of the Note
balance, but that Ms. Arzate needed time to determine if she would hold that equity personally,
or in OpsMD, Inc.’s name. The emails also indicate delay on Ms. Arzate’s part until she and her
DEFENDANTS?’ INITIAL DISCLOSURES PAGE2attorney determined how to legally-acquire the equity in her name, given that OpsMD, Inc., not
her, was the Note’s payee. The agreement to accept MediGain, LLC equity in full exchange for
the Note existed — merely the specifics of the equity transfer remained at issue. Accordingly, no
payments remained due under the Note after the formation of the equity agreement. Plaintiff's
assertions are therefore unfounded.
Rule 194.2(d): the amount and any method of calculating economic damages.
Response: Defendants deny that Plaintiff suffered any damages in connection with
the claims alleged in Plaintiff's First Amended Petition.
Additionally, Defendants seek their reasonable attorneys’ fees and expenses incurred in
connection with defending this matter pursuant to the terms of the Note.
The damages listed above are based upon information or documents that are presently
available to, and specifically known to, Defendants at this time. Defendants have not fully
completed their investigation of the facts relating to this case, have not completed discovery in
this action, and have not completed preparation for trial. It is anticipated that further discovery,
independent investigation, legal research, and analyses will supply additional facts and add
meaning to known facts, which may lead to additions, changes, and variations to this disclosure.
Among other things, Defendants may supplement these disclosures with an updated amount of
damages for the attorneys’ fees Defendants seek to recover.
Rule 194.2(e): the names, addresses, and telephone number of persons having
knowledge of relevant facts, and a brief statement of each
identified person’s connection with the case.
Response:
1, Greg Hackney, Defendant
c/o Jeffrey S. Lowenstein, Esq.
Bell Nunnally & Martin LLP
3232 McKinney Ave., Ste. 1400
Dallas, Texas 75204
Tel: 214-740-1400
Mr. Hackney is the Chief Executive Officer of MediGain, LLC. He possesses personal
knowledge of the Note at issue in this case and was personally involved in its negotiation,
making, and execution. Mr. Hackney also possesses personal knowledge of the
negotiations and communications regarding the agreement with OpsMD, Inc. d/b/a
Ascend Health Services and/or April Arzate to satisfy the remaining Note debt with an
equity interest in MediGain, LLC.
DEFENDANTS?’ INITIAL DISCLOSURES PAGE32. April G. Arzate
OpsMD, Inc.
12741 Research Blvd.
Suite 500
Austin, Texas 78759
Ms. Arzate is the Chief Executive Officer and founder of OpsMD, Inc., and former Vice
President of Client Services for MediGain, LLC. Ms. Arzate possesses personal
knowledge of the Note was personally involved in its negotiation, making, and execution.
Ms. Arzate also possesses personal knowledge of the negotiations and communications
regarding the agreement with MediGain, LLC and Greg Hackney to satisfy the remaining
Note debt with an equity interest in MediGain, LLC.
3. Ray Balestri, Esq.
Bell Nunnally & Martin LLP
3232 McKinney Ave., Ste. 1400
Dallas, Texas 75204
Tel: 214-740-1400
Mr. Balestri is counsel for Defendants. Mr. Balestri possesses knowledge relating to the
Note and the facts and circumstances surrounding the agreement with OpsMD, Inc. d/b/a
Ascend Health Services and/or April Arzate to satisfy the remaining Note debt by
issuance of an equity interest in MediGain, LLC to OpsMD, Inc. d/b/a Ascend Health
Services and/or April Arzate. Most or all of Mr. Balestri’s knowledge related to this case
is subject to the attorney-client and work product privileges.
Rule 194.2(f): for any testifying expert:
qd) the expert’s name, address and telephone number;
(2) __ the subject matter on which the expert will testify;
(3) _ the general substance of the expert’s mental impressions and opinions and a brief
summary of the basis for them, or, or the expert is not retained by, employed by,
or otherwise subject to the control of the responding party, documents reflecting
such information;
(4) __ if the expert is retained by, employed by, or otherwise subject to the control of the
responding party:
(A) all documents, tangible things, reports, models, or data compilations that
have been provided to, reviewed by or prepared by or for the expert in
anticipation of the expert’s testimony; and
(B) The expert’s current resume and bibliography.
DEFENDANTS?’ INITIAL DISCLOSURES PAGE 4Response:
Jeffrey Lowenstein, Esq.
Bell Nunnally & Martin LLP
3232 McKinney Avenue, Suite 1400
Dallas, Texas 75204
(214) 740-1400
Mr. Lowenstein may testify regarding the reasonableness, necessity, and amount of
attorneys’ fees and costs incurred in this matter. The resume for Mr. Lowenstein is attached as
Exhibit A. Mr. Lowenstein is expected to testify that the legal fees and costs incurred by
Defendants in this case were reasonably and necessarily incurred. Mr. Lowenstein may also
opine on Plaintiff’s legal fees and costs and address any other matters relating to attorneys’ fees
and costs. Mr. Lowenstein will review all non-privileged documents and pleadings produced in
this case as well as redacted attorneys’ fees statements.
Defendants reserve the right to retain additional experts and reserve the right to
supplement or amend this response.
Rule 194.2(g): any indemnity and insuring agreements described in Rule 192.3(f).
Response: None.
Rule 194.2(h): any settlement agreements described in Rule 192.3(g).
Response: None.
Rule 194.2(i): any witness statements described in Rule 192.3(h)
Response: None.
Rule 194.2(j): in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records and bills that
are reasonable related to the injuries or damages asserted or, in lieu
thereof, an authorization permitting the disclosure of such medical records
and bills.
Response: Not applicable.
Rule 194.2(k): in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records and bills
DEFENDANTS?’ INITIAL DISCLOSURES PAGESResponse:
Rule 194.2(1):
Response:
DEFENDANTS? INITIAL DISCLOSURES
Not applicable.
obtained by the responding party by virtue of an authorization furnished
by the requesting party.
the name, address and telephone number of any person who may be
designated as a responsible third party.
None that Defendants are aware of, currently.
BELL NUNNALLY & MARTIN LLP
5 Lab
: SLowenstein
S fon 24007574
Alowenstein@belinunnally.com
/ David G.
Texas Bar No, 24081199
davidw@bellnunnally.com
1400 One McKinney Plaza
3232 McKinney Avenue
Dallas, Texas 75204-2429
Phone: 214-740-1400
Fax: 214-740-1499
ATTORNEYS FOR MEDIGAIN, LLC AND
GREG HACKNEY
PAGE 6CERTIFICATE OF SERVICE
This is to certify that on
h 9, 2015, a true and correct copy of the foregoing
document was served on Plaintiff v
LE, as follows:
Ty
J, David Rowe, Esq.
DuBois, Bryant & Campbell, LLP
700 Le a Street, Suite 1300
Austin. Texas 78701
E-mail: drowe@dbellp.com
ATTORNEY FOR OPSMD, INC.
20609531. DOCK.
DEFENDANTS’ INITIAL DISCLOSURES. PAGETSarno
3233 Mokinney Avene
Suite 1400
Dallas, Texas 752
2IA TAD AI Tat
BAT40-57 90.
Practice Areas
Edueation
# University af Caitomia
Los Angeles Schoo! ot
Law J.D, 1a
University of Sabiforias
Los Angeles, 8.4
Admitted to Practice
a Bar of Texas
Appeals, Fifth Circuit
United States Pek
+ the U:
Courts for the North
Souther, Wester
Eastern Distnets of Texas
«All Texas state outs
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Baw
Ausnally & Atte LLP
sins Istotes
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nogument, MuBappronsat ecrets, and raed clowns. Jeit has Wed lawsuits. bot pay an
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© Selerted by ateney 9 ne Bast Lanyers.in Amedcaw, 7
+ Selected by attorney pers for inclusion as Texas Super Lawyer, 2018, 2074
+ Selected by attamey ree as a Tavis Rising Star®, Texas Monthly, 2098 8. 2012 and 2019
= Named on vues in Callas Under 40° by D Atag: 2008
© Senior Editer UGLS Bullewn of Law and Teche
Aativities & Memberships
nib, Gallas Chapter
Texas Genera!
Amorigan Bar Anscetatios, b
+ State Bar of Taxax
any Section
alias Ber Agsscistl
The Hingintratham: ian of
tun! Prdperty Section
Preview
3/9/2015 5:24:02 PM Velva L. Price District Clerk Travis County CAUSE NO. D-1-GN-14-005419 D-1-GN-14-005419 OPSMD, INC. § IN THE DISTRICT COURT § Plaintiff, § § vy. § § TRAVIS COUNTY, TEXAS MEDIGAIN, LLC, GREG HACKNEY, AND PRUDENTIAL INVESTMENTS = § MANAGEMENT, INC. D/B/A § PRUDENTIAL CAPITAL GROUP 8 § Defendants. § 98" JUDICIAL DISTRICT DEFENDANTS’ RESPONSES TO PLAINTIFF’S REQUEST FOR DISCLOSURES To: Plaintiff OpsMD, Inc., by and through its attorney of record, J. David Rowe, Esq., DuBois, Bryant & Campbell, LLP, 700 Lavaca Street, Suite 1300, Austin, Texas 78701. Comes now MediGain, LLC and Greg Hackney (“Defendants”) and serve their Responses to Plaintiff's Request for Disclosures as follows: Rule 194.2(a): the correct names of the parties to the lawsuit. Response: The names of the parties are correct. Rule 194.2(b): the name, address, and telephone number of any potential parties. Response: April G. Arzate of OpsMD, Inc., 12741 Research Blvd., Suite 500, Austin, Texas 78759. Rule 194.2(c): the legal theories and, in general, the factual bases of the responding party’s claims or defenses. Response: The legal theories and supporting facts are based upon information and documents that are presently available to, and specifically known to, Defendants at this time, as well as information and belief that Defendants expect to confirm through discovery. Defendants have not fully completed their investigation of the facts relating to this case, have not completed discovery in this action, and have not completed preparation for trial. It is anticipated that further DEFENDANTS’ INITIAL DISCLOSURES PAGE 1discovery, independent investigation, legal research, and analyses will supply additional facts and add meaning to known facts, which may lead to additions, changes, and variations to the factual bases of Defendants’ legal defense theories. The claims asserted by Plaintiff are without factual or legal merit. Defendants deny each and every, all and singular, material allegation of Plaintiff's First Amended Petition. Specifically, Defendants deny they are liable on the Promissory Note at issue (the “Note”) because the Note lacked consideration and is therefore legally unenforceable. Alternatively, Defendants deny they are liable on the Note because, on information and belief, April G. Arzate committed a prior material breach of her non-competition agreement with MediGain, LLC that absolved Defendants’ duty to continue performing under the Note. Alternatively, Defendants deny they owe any additional payment under the Note because they formed an agreement with Plaintiff and/or April G. Arzate that required Defendants to provide OpsMD, Inc. d/b/a Ascend Health Services and/or April G. Arzate with equity in MediGain, LLC in exchange for the remaining Note balance. The agreement eliminated any further obligation to make Note payments. Multiple documented discussions evidence that this agreement existed but was not finalized due to delay on Ms. Arzate’s part. Such discussions include, but are not limited to, the following: 1. March 13, 2013, email communications between April G. Arzate, Greg Hackney, Chief Executive Officer of MediGain, LLC, and Ray A. Balestri, counsel for MediGain LLC, regarding (1) the official name in which to issue the MediGain, LLC equity units, (2) complications with issuing the MediGain, LLC equity to Ms. Arzate personally because the Note was made payable to OpsMD, Inc. d/b/a Ascend Health Services, and (3) recommendation that Ms. Arzate dividend the Note to the OpsMD, Inc. shareholders (exclusively Ms. Arzate) so she could convert the Note personally into MediGain, LLC equity units. 2. December 17, 2013, email communications between April G. Arzate, Bryan Lee, counsel for Ms. Arzate, and Ray A. Balestri regarding the tax implications for Ms. Arzate for personal receipt of the MediGain, LLC equity. 3. A May 2, 2014, email communication between April G. Arzate, Bryan Lee, and Ray A. Balestri in which Ms. Arzate wrote, “Bryan and I are back on track to get this [equity transfer] completed, and after further discussion on the tax concems, we wanted to request the subscription agreement be resent under OPSMD, Inc. dba Ascend Health service. Also, we’d appreciate a copy of the capitalization table and LLC Agreement.” These emails indicate that Defendants and Plaintiff and/or April G. Arzate formed the agreement to provide equity in MediGain, LLC in exchange for the total amount of the Note balance, but that Ms. Arzate needed time to determine if she would hold that equity personally, or in OpsMD, Inc.’s name. The emails also indicate delay on Ms. Arzate’s part until she and her DEFENDANTS?’ INITIAL DISCLOSURES PAGE2attorney determined how to legally-acquire the equity in her name, given that OpsMD, Inc., not her, was the Note’s payee. The agreement to accept MediGain, LLC equity in full exchange for the Note existed — merely the specifics of the equity transfer remained at issue. Accordingly, no payments remained due under the Note after the formation of the equity agreement. Plaintiff's assertions are therefore unfounded. Rule 194.2(d): the amount and any method of calculating economic damages. Response: Defendants deny that Plaintiff suffered any damages in connection with the claims alleged in Plaintiff's First Amended Petition. Additionally, Defendants seek their reasonable attorneys’ fees and expenses incurred in connection with defending this matter pursuant to the terms of the Note. The damages listed above are based upon information or documents that are presently available to, and specifically known to, Defendants at this time. Defendants have not fully completed their investigation of the facts relating to this case, have not completed discovery in this action, and have not completed preparation for trial. It is anticipated that further discovery, independent investigation, legal research, and analyses will supply additional facts and add meaning to known facts, which may lead to additions, changes, and variations to this disclosure. Among other things, Defendants may supplement these disclosures with an updated amount of damages for the attorneys’ fees Defendants seek to recover. Rule 194.2(e): the names, addresses, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person’s connection with the case. Response: 1, Greg Hackney, Defendant c/o Jeffrey S. Lowenstein, Esq. Bell Nunnally & Martin LLP 3232 McKinney Ave., Ste. 1400 Dallas, Texas 75204 Tel: 214-740-1400 Mr. Hackney is the Chief Executive Officer of MediGain, LLC. He possesses personal knowledge of the Note at issue in this case and was personally involved in its negotiation, making, and execution. Mr. Hackney also possesses personal knowledge of the negotiations and communications regarding the agreement with OpsMD, Inc. d/b/a Ascend Health Services and/or April Arzate to satisfy the remaining Note debt with an equity interest in MediGain, LLC. DEFENDANTS?’ INITIAL DISCLOSURES PAGE32. April G. Arzate OpsMD, Inc. 12741 Research Blvd. Suite 500 Austin, Texas 78759 Ms. Arzate is the Chief Executive Officer and founder of OpsMD, Inc., and former Vice President of Client Services for MediGain, LLC. Ms. Arzate possesses personal knowledge of the Note was personally involved in its negotiation, making, and execution. Ms. Arzate also possesses personal knowledge of the negotiations and communications regarding the agreement with MediGain, LLC and Greg Hackney to satisfy the remaining Note debt with an equity interest in MediGain, LLC. 3. Ray Balestri, Esq. Bell Nunnally & Martin LLP 3232 McKinney Ave., Ste. 1400 Dallas, Texas 75204 Tel: 214-740-1400 Mr. Balestri is counsel for Defendants. Mr. Balestri possesses knowledge relating to the Note and the facts and circumstances surrounding the agreement with OpsMD, Inc. d/b/a Ascend Health Services and/or April Arzate to satisfy the remaining Note debt by issuance of an equity interest in MediGain, LLC to OpsMD, Inc. d/b/a Ascend Health Services and/or April Arzate. Most or all of Mr. Balestri’s knowledge related to this case is subject to the attorney-client and work product privileges. Rule 194.2(f): for any testifying expert: qd) the expert’s name, address and telephone number; (2) __ the subject matter on which the expert will testify; (3) _ the general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or, or the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; (4) __ if the expert is retained by, employed by, or otherwise subject to the control of the responding party: (A) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by or prepared by or for the expert in anticipation of the expert’s testimony; and (B) The expert’s current resume and bibliography. DEFENDANTS?’ INITIAL DISCLOSURES PAGE 4Response: Jeffrey Lowenstein, Esq. Bell Nunnally & Martin LLP 3232 McKinney Avenue, Suite 1400 Dallas, Texas 75204 (214) 740-1400 Mr. Lowenstein may testify regarding the reasonableness, necessity, and amount of attorneys’ fees and costs incurred in this matter. The resume for Mr. Lowenstein is attached as Exhibit A. Mr. Lowenstein is expected to testify that the legal fees and costs incurred by Defendants in this case were reasonably and necessarily incurred. Mr. Lowenstein may also opine on Plaintiff’s legal fees and costs and address any other matters relating to attorneys’ fees and costs. Mr. Lowenstein will review all non-privileged documents and pleadings produced in this case as well as redacted attorneys’ fees statements. Defendants reserve the right to retain additional experts and reserve the right to supplement or amend this response. Rule 194.2(g): any indemnity and insuring agreements described in Rule 192.3(f). Response: None. Rule 194.2(h): any settlement agreements described in Rule 192.3(g). Response: None. Rule 194.2(i): any witness statements described in Rule 192.3(h) Response: None. Rule 194.2(j): in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills that are reasonable related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills. Response: Not applicable. Rule 194.2(k): in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills DEFENDANTS?’ INITIAL DISCLOSURES PAGESResponse: Rule 194.2(1): Response: DEFENDANTS? INITIAL DISCLOSURES Not applicable. obtained by the responding party by virtue of an authorization furnished by the requesting party. the name, address and telephone number of any person who may be designated as a responsible third party. None that Defendants are aware of, currently. BELL NUNNALLY & MARTIN LLP 5 Lab : SLowenstein S fon 24007574 Alowenstein@belinunnally.com / David G. Texas Bar No, 24081199 davidw@bellnunnally.com 1400 One McKinney Plaza 3232 McKinney Avenue Dallas, Texas 75204-2429 Phone: 214-740-1400 Fax: 214-740-1499 ATTORNEYS FOR MEDIGAIN, LLC AND GREG HACKNEY PAGE 6CERTIFICATE OF SERVICE This is to certify that on h 9, 2015, a true and correct copy of the foregoing document was served on Plaintiff v LE, as follows: Ty J, David Rowe, Esq. DuBois, Bryant & Campbell, LLP 700 Le a Street, Suite 1300 Austin. Texas 78701 E-mail: drowe@dbellp.com ATTORNEY FOR OPSMD, INC. 20609531. DOCK. DEFENDANTS’ INITIAL DISCLOSURES. PAGETSarno 3233 Mokinney Avene Suite 1400 Dallas, Texas 752 2IA TAD AI Tat BAT40-57 90. Practice Areas Edueation # University af Caitomia Los Angeles Schoo! ot Law J.D, 1a University of Sabiforias Los Angeles, 8.4 Admitted to Practice a Bar of Texas Appeals, Fifth Circuit United States Pek + the U: Courts for the North Souther, Wester Eastern Distnets of Texas «All Texas state outs RS) BELLNUNNALLY un. Baw Ausnally & Atte LLP sins Istotes all Nureally & id indivikiats. in 3 vant commnerein management feasi pu 3 content ts. thera. ws lawsuits ievelving intellectual propery clams. ap nogument, MuBappronsat ecrets, and raed clowns. Jeit has Wed lawsuits. bot pay an fusing state court, federal comt, bankruptey cout, and arbitration, J pusiness Ss pur aes overs in claus invelving inaysnip disputes, He nehuing patent copyright, anc tade tamed sun evolving tet + Obtmnws settlement evolving client's alleged ya equipment ang sottware patent infringement on bobalt icf inmate te! gment at th provider toile. leense ag’ ne provider ie Migation Fegerat Ch 3 @ five week jury tal in erent snwalving 18 tel case amate ws ecommunicatians termination of a pate « -Qhtained settlement for design patest bolder agdinst a multinational al commany in decta brovatt to inval . latnporery injunction preventing inteferance with customer contracts bas Infiagement-of dentitication vortication software copyrights, * waning return of sompany demain name it ongaing htigation . traded domain eaune end eaciomark for 1 i pnat media ¥. . developer againet 2 tate trains claims selating 10 purported nodisclosurd of sroperty. > 2 jury warehet Gn bea ie was otleged to hace ciused property damages va asa plait a:sentienen Served a saboral coostinating counsel for inmate tele cosedinating ret deepotes with. compe ieeougtiout th + Beprosented raed Safety Commissic da reversal et a8 «Gn bekalf of an macnn trection detect clair, Sonmunications provicer is bukenng, 6 ano involving public contacts with ae tating, and NS of egmection g and Re ional pividurt recall an 900 dict on behalf of a medica! eguipmas Noteworthy * Jeff sen ak a member ot Bel Nunnally’s Manager © Selerted by ateney 9 ne Bast Lanyers.in Amedcaw, 7 + Selected by attorney pers for inclusion as Texas Super Lawyer, 2018, 2074 + Selected by attamey ree as a Tavis Rising Star®, Texas Monthly, 2098 8. 2012 and 2019 = Named on vues in Callas Under 40° by D Atag: 2008 © Senior Editer UGLS Bullewn of Law and Teche Aativities & Memberships nib, Gallas Chapter Texas Genera! Amorigan Bar Anscetatios, b + State Bar of Taxax any Section alias Ber Agsscistl The Hingintratham: ian of tun! Prdperty Section