On July 12, 2021 a
Answer
was filed
involving a dispute between
Seaspine Sales Llc,
and
Ethicus Hospital Dfw Llc,
Psn Affiliates, Llc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
8/6/2021 11:36 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Miranda Lynch DEPUTY
CAUSE NO. DC-21-08988
SEASPINE SALES LLC IN THE DISTRICT COURT
Plaintiff
V. 116TH JUDICIAL DISTRICT
PSN AFFILIATES, LLC AND
ETHICUS HOSPITAL DFW LLC D/B/A
LEGENT ORTHOPEDIC HOSPITAL
F/D/B/A SAGECREST HOSPITAL
CARROLLTON
Defendants DALLAS COUNTY, TEXAS
DEFENDANTS’ ORIGINAL ANSWER AND REQUEST FOR DISCLOSURE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC
D/B/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL
CARROLLTON, Defendants herein, and file this Original Answer to Plaintiff’s Original
Petition on file herein and would respectfully show the Court as follows:
I.
GENERAL DENIAL
Defendants deny each and every, all and singular, the allegations contained within
Plaintiff’s Original Petition and demand strict proof thereof.
II.
REQUEST FOR DISCLOSURE
Pursuant to Rule 194, Texas Rules of Civil Procedure, Plaintiff. is requested to disclose
to Defendants, within thirty (30) days of service of this Request, the information or material
described in Rule 194.2.
WI-IEREFORE, PREMISES CONSIDERED, Defendants PSN AFFILIATES, LLC
AND ETHICUS HOSPITAL DFW LLC D/B/A LEGENT ORTHOPEDIC HOSPITAL
F/D/B/A SAGECREST HOSPITAL CARROLLTON pray that upon final hearing hereof,
Plaintiff take nothing by Plaintiff’s Original Petition, that Defendants go hence Without day, and
have and recover such other and further relief, at law and in equity, general and special, to which
Defendants may be shown justly entitled to receive.
Respectfiilly submitted,
LAW OFFICES OF M. DREW SIEGEL
/s/ M Drew Siege]
By:
M. DREW SIEGEL
State Bar No. 18342150
12830 Hillcrest Rd., Ste. 231
Dallas, Texas 75230
972/982-0410
Fax: 972/960-1476
drewsiegel@aol.com
Attorney for Defendants
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing Original Answer
has been served upon opposing counsel in this cause in accordance with the Texas Rules of Civil
Procedure, this 6th day of August, 2021.
/s/ M Drew Siege]
M. DREW SIEGEL
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Drew Siegel on behalf of M Drew Siegel
Bar No. 18342150
drew@drewsiegellaw.com
Envelope ID: 56072256
Status as of 8/9/2021 9:50 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
MARK ABUKATY bu katyatty@aol.com 8/6/2021 11:36:54 AM SENT
Document Filed Date
August 06, 2021
Case Filing Date
July 12, 2021
Category
CNTR CNSMR COM DEBT
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FILED 8/6/2021 11:36 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Miranda Lynch DEPUTY CAUSE NO. DC-21-08988 SEASPINE SALES LLC IN THE DISTRICT COURT Plaintiff V. 116TH JUDICIAL DISTRICT PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC D/B/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL CARROLLTON Defendants DALLAS COUNTY, TEXAS DEFENDANTS’ ORIGINAL ANSWER AND REQUEST FOR DISCLOSURE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC D/B/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL CARROLLTON, Defendants herein, and file this Original Answer to Plaintiff’s Original Petition on file herein and would respectfully show the Court as follows: I. GENERAL DENIAL Defendants deny each and every, all and singular, the allegations contained within Plaintiff’s Original Petition and demand strict proof thereof. II. REQUEST FOR DISCLOSURE Pursuant to Rule 194, Texas Rules of Civil Procedure, Plaintiff. is requested to disclose to Defendants, within thirty (30) days of service of this Request, the information or material described in Rule 194.2. WI-IEREFORE, PREMISES CONSIDERED, Defendants PSN AFFILIATES, LLC AND ETHICUS HOSPITAL DFW LLC D/B/A LEGENT ORTHOPEDIC HOSPITAL F/D/B/A SAGECREST HOSPITAL CARROLLTON pray that upon final hearing hereof, Plaintiff take nothing by Plaintiff’s Original Petition, that Defendants go hence Without day, and have and recover such other and further relief, at law and in equity, general and special, to which Defendants may be shown justly entitled to receive. Respectfiilly submitted, LAW OFFICES OF M. DREW SIEGEL /s/ M Drew Siege] By: M. DREW SIEGEL State Bar No. 18342150 12830 Hillcrest Rd., Ste. 231 Dallas, Texas 75230 972/982-0410 Fax: 972/960-1476 drewsiegel@aol.com Attorney for Defendants CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the foregoing Original Answer has been served upon opposing counsel in this cause in accordance with the Texas Rules of Civil Procedure, this 6th day of August, 2021. /s/ M Drew Siege] M. DREW SIEGEL Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Drew Siegel on behalf of M Drew Siegel Bar No. 18342150 drew@drewsiegellaw.com Envelope ID: 56072256 Status as of 8/9/2021 9:50 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status MARK ABUKATY bu katyatty@aol.com 8/6/2021 11:36:54 AM SENT