Preview
153-319423-20
EXHIBIT A
Case 4:20-cv-01103-O Document 1 Filed 10/06/20 Page 1 of 5 PageID 1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
TEXAS HEALTH RESOURCES, §
§
Plaintiff, §
v. §
CIVIL ACTION NO. 4:20-cv-1103
§
AETNA HEALTH, INC., §
§
Defendant. §
NOTICE OF REMOVAL OF CIVIL ACTION
Defendant Aetna Health Inc. (“AHI” or “Defendant”) files this Notice of Removal of the
civil action brought against itby Plaintiff Texas Health Resources (“Plaintiff” or” THR”). The
grounds in support of this Notice of Removal are as follows:
1. The State Court Action, Parties and Pleadings. On September 3, 2020, Plaintiff
filed its Original Petition (the “Complaint”) against Defendant in the 153rd Judicial District Court
of Tarrant County, Texas, under Cause No. 153-319423-20 (the “State Court Action”). A true and
correct copy of the Complaint is attached hereto as Exhibit B.1
2. Defendant was served with or otherwise received a copy of the Complaint on
September 9, 2020. A true and correct copy of the citation is attached hereto as Exhibit D.
3. To avoid the entry of a default judgment, Defendant filed a Motion to Transfer
Venue and its Original Answer on October 2, 2020. A true and correct copy of which is attached
hereto as Exhibit F.
1
Pursuant to LR 81.1 of the Local Rules of the United States District Court for the Northern District
of Texas, Defendant has attached an index of all attached documents, a copy of the state court docket
(attached hereto as Exhibit A), each document filed in the state court action, and a signed certificate of
interested parties (attached hereto as Exhibit H).
Case 4:20-cv-01103-O Document 1 Filed 10/06/20 Page 2 of 5 PageID 2
4. This Notice is Timely Pursuant to 28 U.S.C. § 1446(b). This Notice of Removal
of Civil Action is being filed prior to the expiration of the statutorily-allowed thirty (30) day period
after the date Defendant was served with or otherwise received a copy of the Complaint.
5. ERISA Complete Preemption Raises a Federal Question. The Complaint
necessarily raises a federal claim in character because ERISA 2 completely preempts Plaintiff’s
state law claims as set forth below. Therefore, the State Court Action may be removed to this Court
because it arises under the laws of the United States.
6. More specifically, in its Complaint, Plaintiff asserts that it filed this “breach of
contract case against Aetna for [allegedly] denying or underpaying 16 Accounts . . . of patients
with health coverage issued or administered by Aetna.” 3 According to the Complaint, the parties
entered into a Hospital Services Agreement (“HSA”). 4 The Complaint further alleges that the 16
patients were “Covered Persons,” and the services provided were “Covered Services,” as defined
in the HSA. 5 “As a result,” the Complaint states, “Aetna was contractually liable under the HSA
to pay THR . . . at the contracted rate set out in the HSA, 6 and Plaintiff contends that the (alleged)
failure “to pay the contractual rate was a breach of the HSA.” 7 With respect to several of the
alleged “Patient Accounts,” however, Plaintiff is challenging Aetna’s determinations regarding
2
Employee Retirement Income Security Act of 1974, as amended, 29 U.S.C. §§ 1001-1461.
3
Exhibit B, p. 1, ¶1.
4
Exhibit B, p. 2, ¶8. See The parties originally entered into a Hospital Services Agreement,
effective September 15, 2005, and then entered into a subsequent Facility Services Agreement, effective
September 1, 2017. Some of the services at issue were after September 1, 2017, but the later Agreement
contains similar terms as those described by Plaintiff in paragraph 8.
5
Exhibit B, p. 2, ¶8.
6
Exhibit B, pp. 2-3, ¶8.
7
Exhibit B, p. 3, ¶8.
-2-
Case 4:20-cv-01103-O Document 1 Filed 10/06/20 Page 3 of 5 PageID 3
coverage under the terms of the patient’s underlying health benefit plan, including, but not limited
to, determinations regarding whether services are medically necessary.
7. For a number of these Patient Accounts, Aetna denied payment for services because
they were not covered under the terms of the patient’s health benefit plan, including health benefit
plans at issue in this case that are governed by ERISA. As such, they were not “Covered Services”
under the HSA, and by suing on those determinations in this suit, Plaintiff is implicating Aetna’s
coverage determinations under ERISA plans. Moreover, Plaintiff is challenging the right to
payment of these claims, rather than simply the agreed-upon rate of payment under the HSA.
Therefore, under controlling case law, Plaintiff’s state law claims are completely preempted. 8
8. As an assignee of the patients’ rights to payment of ERISA plan benefits, if any,
Plaintiff could have brought its claims under the civil enforcement provisions of ERISA.
Furthermore, Plaintiff’s state law claims are not based on any duty independent of ERISA and/or
the plans’ terms. 9
9. Therefore, Plaintiff asserts state law claims that are completely preempted by
ERISA’s civil enforcement scheme, codified at 29 U.S.C. § 1132(a). This Court has original
jurisdiction over such claims pursuant to 28 U.S.C. §1331 and 29 U.S.C. §1132(e), and the matter
is one that may be removed pursuant to 28 U.S.C. §1441(a) and/or §1441(c) and controlling case
law. See Metro. Life Ins. Co. v. Taylor, 481 U.S. 58 (1987) (holding state court action asserting
8
See Lone Star OB/GYN Assocs. v. Aetna Health Inc., 579 F.3d 525, 531 (5th Cir. 2009) (noting
that Aetna is correct in that “any determination of benefits under the terms of a plan—i.e., what is ‘medically
necessary’ or a ‘Covered Service’—does fall within ERISA).
9
See Aetna Health Inc. v. Davila, 542 U.S. 200, 209-11 (2004); Pilot Life Ins. Co. v. Dedeaux, 481
U.S. 41, 56-57 (1987). A claim falls within the scope of 29 U.S.C. § 1132(a) and is completely preempted
by ERISA if (1) the plaintiff, at some point in time, could have brought the claim under ERISA, and (2)
there is no other legal duty independent of ERISA or the plan’s terms that is implicated by a defendant’s
actions. Davila, 542 U.S. at 210. Both elements are satisfied here.
-3-
Case 4:20-cv-01103-O Document 1 Filed 10/06/20 Page 4 of 5 PageID 4
only state law causes of action relating to alleged failure to pay a claim for benefits under an
employee benefit plan constitutes a federal question and is removable to federal court).
10. Alternatively, this Court has supplemental jurisdiction over any state law claims
against Defendant arising out of medical claims that are not completely preempted. 28 U.S.C. §
1367(a). 10
11. Notice Filed in the State Court. Promptly after filing this Notice of Removal,
Defendant will provide written notice of removal to Plaintiff’s counsel and will file a copy of this
Notice of Removal with the Clerk for the District Court of Tarrant County. 11
WHEREFORE, Defendant Aetna Health Inc. prays that the State Court Action be removed
to the United States District Court for the Northern District of Texas, Fort Worth Division.
10
As it relates to individual medical claims, complete diversity of citizenship confers jurisdiction
pursuant to 28 U.S.C. § 1332. AHI was not the claims administrator for plans at issue and had no role in
those medical claims at issue. The Aetna affiliate that was the third-party claims administrator for the
respective plans is not a citizen of the state of Texas, and the amount in controversy exceeds $75,000.00.
11
A true and correct copy of the Notice being filed with the district Court of Tarrant County, Texas,
is attached hereto as Exhibit G.
-4-
Case 4:20-cv-01103-O Document 1 Filed 10/06/20 Page 5 of 5 PageID 5
OF COUNSEL: Respectfully submitted,
HUNTON ANDREWS KURTH LLP
and By: s/ M. Katherine Strahan
JOHN B. SHELY M. KATHERINE STRAHAN
State Bar No.18215300 State Bar No. 24013584
jshely@HuntonAK.com kstrahan@HuntonAK.com
600 Travis, Suite 4200
Houston, Texas 77002
Telephone: (713) 220-4105
Facsimile: (713) 220-4285
ATTORNEY-IN-CHARGE FOR DEFENDANT
AETNA HEALTH INC.
KARIN CAGLE
State Bar No. 24043588
kcaglelaw@gmail.com
1619 Pennsylvania Avenue
Fort Worth, Texas 76104
Telephone: (817) 721-5127
LOCAL COUNSEL FOR DEFENDANT
AETNA HEALTH INC.
CERTIFICATE OF SERVICE
I hereby certify that on October 6, 2020, I electronically filed the foregoing document with
the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case
filing system of the court, and that a true and correct copy of this document was also sent to the
following attorneys of record by United States certified mail and electronic mail, on October 6,
2020, as follows:
Blair G. Francis
Blair.francis@ftllplaw.com
Nickelette P. Lotspeign
Nickel.lotspeich@ftllplaw.com
FRANCIS & TOTUSEK LLP
500 N. Akard Street, Suite 1830
Dallas, Texas 75201
s/ M. Katherine Strahan
M. Katherine Strahan
-5-
JS 44(Rev. 06/17) - TXND (Rev. 06/17) CIVIL COVER SHEET
Case 4:20-cv-01103-O Document 1-1 Filed 10/06/20 Page 1 of 2 PageID 6
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet.
(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Texas Health Resources Aetna Health Inc.
(b) Tarrant County
County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
See Attachment See Attachment
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 ’
Incorporated or Principal Place
4 ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity ’
Citizen of Another State 2 ’ 2 ’
Incorporated and Principal Place
5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
’
Citizen or Subject of a 3 ’ 3 Foreign Nation ’ 6 ’ 6
Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure
’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - ’ 423 Withdrawal
of Property 21 USC 881 ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product ’ 690 Other
Product Liability 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ ’
150 Recovery of Overpayment
320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated
’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards
’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ ’
195 Contract Product Liability
360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation
FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil RightsHabeas Corpus: ’ 791 Employee Retirement
’ 870 Taxes (U.S. Plaintiff
’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ ’
230 Rent Lease & Ejectment442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ ’
290 All Other Real Property ’ 535 Death Penalty
445 Amer. w/Disabilities - IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ ’ 540 Mandamus & Other
446 Amer. w/Disabilities - ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’1 Original ’2 Removed from ’ 3 Remanded from ’ 4 ’
Reinstated or ’
5 Transferred from 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Aetna Health Inc. removes this lawsuit under 29 U.S.C. § 1132
VI. CAUSE OF ACTION Brief description of cause:
Plaintiff challenges coverage and benefit determinations under the terms of ERISA plans.
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
10/06/2020 s/M. Katherine Strahan
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
Print Save As... Reset
JS 44 Reverse (Rev. 06/17) - TXND (Rev. 06/17)
Case 4:20-cv-01103-O Document 1-1 Filed 10/06/20 Page 2 of 2 PageID 7
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court.
This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet.
Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed.
The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants.Enter names (last, first, middle initial) of plaintiff and defendant.
If the plaintiff or defendant is a government agency,
use only the full name or standard abbreviations.
If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at
the time of filing.
In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing.
(NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record.
If there are several attorneys, list them on an attachment,
noting in this section "(see attachment)".
II. Jurisdiction.The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings.
Place an
"X" in one of the boxes.
If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff.
(1) Jurisdiction based on 28 U.S.C. 1345 and 1348.
Suits by agencies and officers of the United States are included here.
United States defendant.
(2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question.(3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States.
In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship.
(4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states.
When Box 4 is checked, the
(See Section III below; NOTE: federal question actions take precedence over diversity
citizenship of the different parties must be checked.
cases.)
III. Residence (citizenship) of Principal Parties.
This section of the JS 44 is to be completed if diversity of citizenship was indicated above.
Mark
this section for each principal party.
IV. Nature of Suit.Place an "X" in the appropriate box.
If there are multiple nature of suit codes associated with the case, pick the nature of suit
code that is most applicable.
Click here for: Nature of Suit Code Descriptions.
V. Origin. Place an "X" in one of the seven boxes.
Original Proceedings.(1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action.
Use the date of remand as the filing
date.
Reinstated or Reopened.(4) Check this box for cases reinstated or reopened in the district court.
Use the reopening date as the filing date.
Transferred from Another District.
(5) For cases transferred under Title 28 U.S.C. Section 1404(a).
Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer.
(6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File.
(8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Do not cite
Report the civil statute directly related to the cause of action and give a brief description of the cause.
jurisdictional statutes unless diversity.
Example: U.S. Civil Statute: 47 USC 553Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action.Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any.
If a related case exists, whether pending or closed,
insert the docket numbers and the corresponding judge names for such cases. A case is related to this filing if the case: 1) involves some or all of the
same parties and is based on the same or similar claim; 2) involves the same property, transaction, or event; 3) involves substantially similar issues of
law and fact; and/or 4) involves the same estate in a bankruptcy appeal.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case 4:20-cv-01103-O Document 1-2 Filed 10/06/20 Page 1 of 2 PageID 8
Supplemental Civil Cover Sheet
Page 1 of 2
Supplemental Civil Cover Sheet for Cases Removed
From State Court
This form must be attached to the Civil Cover Sheet at the time the case is filed in the U.S. District
Clerk’s Office. Additional sheets may be used as necessary.
1. State Court Information:
Please identify the court from which the case is being removed and specify the number assigned
to the case in that court.
Court Case Number
153rd Judicial District Court, Tarrant County, Texas 153-319423-20
2. Style of the Case:
Please include all Plaintiff(s), Defendant(s), Intervenor(s), Counterclaimant(s), Crossclaimant(s)
and Third Party Claimant(s) still remaining in the case and indicate their party type. Also, please
list the attorney(s) of record for each party named and include their bar number, firm name,
correct mailing address, and phone number (including area code).
Party and Party Type Attorney(s)
Texas Health Resources, Plaintiff Blair G. Francis (Bar # 07354900), Nickelette P.
Lotspeich (Bar # 24094233), FRANCIS & TOTUSEK
LLP, 500 N Akard St. Dallas, TX 75201, (214)740-4250
Aetna Health Inc., Defendant M. Katherine Strahan (Bar # 24013584), John B. Shely
(Bar # 18215300) HUNTON ANDREWS KURTH, LLP
600 Travis St., Suite 4200, Houston, TX 77002, (712)
3. Jury Demand: 220-4200; Karin Cagle (Bar # 24043588), 1619 Pennsylvania
Ave., Fort Worth, TX 76104 (817) 721-5127
Was a Jury Demand made in State Court? Yes ✔ No
If “Yes,” by which party and on what date?
___________________________________ ______________________
Party Date
Case 4:20-cv-01103-O Document 1-2 Filed 10/06/20 Page 2 of 2 PageID 9
Supplemental Civil Cover Sheet
Page 2 of 2
4. Answer:
Was an Answer made in State Court? ✔ Yes No
If “Yes,” by which party and on what date?
Defendant
___________________________________ 10/02/2020
______________________
Party Date
5. Unserved Parties:
The following parties have not been served at the time this case was removed:
Party Reason(s) for No Service
N/A.
6. Nonsuited, Dismissed or Terminated Parties:
Please indicate any changes from the style on the State Court papers and the reason for that
change:
Party Reason
N/A.
7. Claims of the Parties:
The filing party submits the following summary of the remaining claims of each party in this
litigation:
Party Claim(s)
Plaintiff Plaintiff challenges coverage and benefit determinations
under the terms of ERISA plans.
Defendant None at this time.
Case 4:20-cv-01103-O Document 1-3 Filed 10/06/20 Page 1 of 1 PageID 10
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
TEXAS HEALTH RESOURCES, §
§
Plaintiff, §
§
v. §
CIVIL ACTION NO. ______
§
AETNA HEALTH INC., §
§
Defendant. §
§
INDEX OF DOCUMENTS BEING FILED
WITH THE NOTICE OF REMOVAL
Civil Cover Sheet
Supplemental Civil Cover Sheet
Exhibit Exhibits to the Notice of Removal Date Filed
A. State Court Docket Sheet n/a
B. Plaintiff’s Original Petition and Request for Disclosure September 3, 2020
C. Service Request Form September 4, 2020
D. Citation to Aetna Health Inc. September 9, 2020
E. Return of Service to Aetna Health Inc. September 10, 2020
F. Defendant’s Motion to Transfer Venue and Original October 2, 2020
Answer
G. Notice of Removal of State Court Action
H. Certificate of Interested Persons
Case 4:20-cv-01103-O Document 1-4 Filed 10/06/20 Page 1 of 3 PageID 11
EXHIBIT A
012323131 4566578 78
Case 4:20-cv-01103-O Document 1-4 Filed 10/06/20 Page 2 of 3 PageID 12
+,-,.%+/01%/23%45/20/67,82%92:85;/7,82 !"#"$#$"$"%!$&'(%)*
<=>?@AB CDE XHY@GAZ[\]
GHA[>X^H?ABA_`aba_cdeabef % WF@HAgUhHiABAfcbfabefef
4jklL%mjln4m%ojLpqo+jL rAsQArlj4Nl%mjln4mt%9N+u
GHA=vAwV@U=YAB%+pN4ol+4t%p4mjo%xjy4#+pN4ol+4
GAB%)jNx9Nz
gUhHA{F?| WHGV?U}@U=Y A wGGHGGHiAgHH