CAUSE NO. DC-22-07513
`
`;
`TROY CONTRERAS,
`on behalf of himself and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS, LLC,
`d/b/a BAPTIST HEALTH SYSTEM,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`193rd JUDICIAL DISTRICT
`
`CAUSENO. DC-22-07814
`
`NORMALOPEZ,
`on behalf of herself and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS, LLC,
`d/b/a BAPTIST HEALTH SYSTEM,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`160th JUDICIAL DISTRICT
`
`
`
`;
`TROY CONTRERAS,
`on behalf of himself and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS, LLC,
`d/b/a BAPTIST HEALTH SYSTEM,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`193rd JUDICIAL DISTRICT
`
`CAUSENO. DC-22-07814
`
`NORMALOPEZ,
`on behalf of herself and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS, LLC,
`d/b/a BAPTIST HEALTH SYSTEM,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`160th JUDICIAL DISTRICT
`
`
`
`CAUSE NO. DC-22-07885
`
`CHARLES EARLEY
`on behalf of himself and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS, LLC,
`dba BAPTIST HEALTH SYSTEM,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`160th JUDICIAL DISTRICT
`
`CAUSENO. DC-22-07963
`
`TOBY BURRELL,
`on behalf of himself and on behalf of all others
`similarly situated,
`
`Plaintiff,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`
`:
`
`,
`
`IN THE DISTRICT COURT OF
`
`DALLAS COUNTY, TEXAS
`
`Defendant.
`14th JUDICIAL DISTRICT
`
`
`
`CAUSE NO. DC-22-08056
`
`KEN CARLSEN and MARY VASQUEZ,
`on behalf of themselves and on behalf of all others
`similarly situated,
`
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiffs,
`
`Vv.
`
`TENET HEALTHCARE CORPORATION,
`and VHS SAN ANTONIO PARTNERS,L.L.C.,
`dba Baptist Health System,
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`
`
`14th JUDICIAL DISTRICT
`
`CAUSE NO. DC-22-08226
`
`AIMEE LADNER,individually and as natural
`parent and next friend of E.W., a minor, and
`ELIZABETH LADNER,individually and on
`behalf of all others similarly situated
`
`:
`:
`
`IN THE DISTRICT COURT OF
`
`Plaintiffs,
`
`V.
`
`TENET HEALTHCARE CORPORATION,
`VHS SAN ANTONIO PARTNERS LLC
`d/b/a BAPTIST HEALTH SYSTEM,and
`RESOLUTE HOSPITAL COMPANY, LLC
`d/b/a RESOLUTE HEALTH HOSPITAL
`
`DALLAS COUNTY, TEXAS
`
`Defendants.
`193rd JUDICIAL DISTRICT
`
`[PROPOSED] ORDER CONSOLIDATING ACTIONS
`
`
`
`Plaintiffs’ Unopposed Motion to Transfer and Consolidate Cases having been read and
`
`considered, and it appearing to the Court that there are common questions of law and fact and that
`
`consolidation will avoid expense and delay for good cause shown, the Court hereby GRANTSthe
`
`Motion and ORDERSthe following:
`
`1.
`
`Contreras v. Tenet Healthcare Corporation and VHS San Antonio Partners LLC,
`
`d/b/a Baptist Health System, No. DC-22-07513, filed July 5, is hereby consolidated with Aimee
`
`Ladner and Elizabeth Ladner v. Tenet Healthcare Corporation, VHS San Antonio Partners LLC
`
`d/b/a Baptist Health System, and Resolute Hospital Company, LLC d/b/a Resolute Health
`
`Hospital, No. DC-22-08226,filed July 19, 2022 in the 193" Judicial District (hereafter the “Ladner
`
`Action”), Burrell v. Tenet Healthcare Corporation, No. DC-22-07963, filed on July 12, 2022 in
`
`the 14™ Judicial District (hereinafter, the “Burrell Action”), 2022, Ken Carlson and Mary Vasquez
`
`v. Tenet Healthcare Corporation and VHS San Antonio Partners, L.L.C. dba Baptist Health
`
`System, No. DC-22-08056, filed July 13, 2022 in the 14" Judicial District Court (hereafter the
`
`“Carlson Action”), Charles Earley v. Tenet Healthcare Corporation and VHS San Antonio
`
`Partners, LLC, dba Baptist Health System, No. DC-22-07885, filed July 11, 2022 in the 160%
`
`Judicial District (hereinafter, the “Earley Action”), and Lopez v. Tenet Healthcare Corporation
`
`and VHS San Antonio Partners, LLC d/b/a Baptist Health System, Case No. DC-22-07814, filed
`
`on July 11, 2022 in the 160" Judicial District (hereinafter, the “Lopez Action”) for all purposes.
`
`2.
`
`Thereafter,
`
`the Ladner, Burrell, Carlson, Earley, and Lopez Actions will be
`
`administratively closed and will proceed under No. DC-22-07513 as a consolidated action with
`
`the Contreras v. Tenet Healthcare Corporation.
`
`3.
`
`All papers filed in the Consolidated Action shall be filed under Case No. DC-22-
`
`07513 and shall bear the following caption:
`
`
`
`HEALTHCARE
`TENET
`RE:
`IN
`CORPORATION
`DATA
`BREACH
`LITIGATION
`
`
`
`Case No. DC-22-07513
`
`4.
`
`Each new casethat arises out of the subject matter of the Contreras consolidated
`
`Action which is filed in this Court or transferred to this Court, shall be consolidated with the
`
`Contreras Action and this Order shall apply thereto, unless a party objects to consolidation, as
`
`provided for herein, or any provision of this Order, within ten (10) days after the date upon which
`
`a copy of this Order is served on counsel for such party, by filing an application for relief and this
`
`Court deemsit appropriate to grant such application. Nothing in the forgoing shall be construed as
`
`a waiver of Defendant’s right to object to consolidation of any subsequently-filed or transferred
`
`related action;
`
`5.
`
`Any motions for appointmentof interim class counsel shall be filed within fourteen
`
`(14) days after the entry of this Order. No response briefs shall be accepted;
`
`6.
`
`Plaintiffs shall file a consolidated amended complaint within thirty (30) days of the
`
`Court’s entry of an Order appointing interim class counsel; and,
`
`7.
`
`Defendants shall have 30 days from the filing of the consolidated amended
`
`complaint to answer or otherwise respond to the consolidated amended complaint, and Defendants’
`
`deadline to file a motion to dismiss under Rule 91a of the Texas Rules of Civil Procedure shall be
`
`30 days from the filing of the consolidated amended complaint.
`
`If Defendants file a Rule 9la
`
`motion, Plaintiffs’ opposition shall be due 30 days from the filing of the motion, and Defendants
`
`shall then have 21 daysto file a reply in support. Any hearing on a Rule 91a motion shall not be
`
`set until after Defendants file a reply in support. All parties agree that compliance with these
`
`
`
`deadlines shall not affect or waive Defendants’ rights under Rule 91a even if different than the
`
`deadlines prescribed in Rule 91a.
`
`8.
`
`This Order applies to all actions included in the above-captioned consolidated
`
`matters and all subsequently consolidated actions.
`
`SO ORDERED this _day of August, 2022.
`
`
`
`
`
`Automated Certificate of eService
`This automatedcertificate of service was created bythe efiling system. The filer served this
`document via email generated by the efiling system on the date and to the personslisted below.
`The rules governing certificates of service have not changed. Filers muststill provide a certificate
`of service that complies with all applicable rules.
`
`Joe Kendall
`
`Bar No. 11260700
`administrator@kendalllawgroup.com
`Envelope ID: 67117664
`Status as of 8/10/2022 10:23 AM CST
`
`Case Contacts
`
`Name
`Gary Klinger
`Helena Gurtu
`
`BarNumber
`
`gklinger@milberg.com
`hgurtu@kendalllawgroup.com
`
`TimestampSubmitted
`8/9/2022 4:33:26 PM
`8/9/2022 4:33:26 PM
`
`Status
`
`SENT
`
`SENT
`
`
`
`Automated Certificate of eService
`This automatedcertificate of service was created bythe efiling system. The filer served this
`document via email generated by the efiling system on the date and to the personslisted below.
`The rules governing certificates of service have not changed. Filers muststill provide a certificate
`of service that complies with all applicable rules.
`
`Joe Kendall
`
`Bar No. 11260700
`administrator@kendalllawgroup.com
`Envelope ID: 67117664
`Status as of 8/10/2022 10:23 AM CST
`
`Associated Case Party: TROY CONTRERAS
`Name
`BarNumber
`Joe Kendall
`jkendall@kendalllawgroup.com
`
`TimestampSubmitted
`8/9/2022 4:33:26 PM
`
`Status
`
`SENT
`
`
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