Electronically Filed
`8/23/2023 9:37 AM
`Hidalgo County District Clerks
`Reviewed By: Rubie Ortega
`
`CAUSE NO. C-0649-23-L
`
` IN THE DISTRICT COURT
`
`
`
` 464TH JUDICIAL DISTRICT
`
`MARCO DELEON AND
`BETTY DELEON,
` Plaintiffs,
`
`v.
`
`ERNESTO E. ROSILES AND
`SPACE EXPLORATION
`TECHNOLOGIES CORP.,
` Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`DEFENDANTS’ NOTICE OF SERVICE OF COUNTER-AFFIDAVITS
`
`
`
` HIDALGO COUNTY, TEXAS
`
`
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`COME NOW Space Exploration Technologies Corporation and Ernesto E. Rosiles,
`
`Defendants in the above styled and numbered cause of action, and file this Notice pursuant to
`
`Texas Civil Practice and Remedies Code 18.001.
`
`Defendants state the following counter-affidavits were served on Plaintiffs on July 24,
`
`2023:
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Valley
`Regional Medical Center pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Rio
`Grande Valley Interventional Pain pertaining to Plaintiff Betty Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Insight
`Diagnostics & Imaging pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at
`Singleton Associates PA pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Khit
`Chiropractic and Wellness Center pertaining to Plaintiff Betty Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Kay
`Medical Center pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`
`8/23/2023 9:37 AM
`Hidalgo County District Clerks
`Reviewed By: Rubie Ortega
`
`CAUSE NO. C-0649-23-L
`
` IN THE DISTRICT COURT
`
`
`
` 464TH JUDICIAL DISTRICT
`
`MARCO DELEON AND
`BETTY DELEON,
` Plaintiffs,
`
`v.
`
`ERNESTO E. ROSILES AND
`SPACE EXPLORATION
`TECHNOLOGIES CORP.,
` Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`DEFENDANTS’ NOTICE OF SERVICE OF COUNTER-AFFIDAVITS
`
`
`
` HIDALGO COUNTY, TEXAS
`
`
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`COME NOW Space Exploration Technologies Corporation and Ernesto E. Rosiles,
`
`Defendants in the above styled and numbered cause of action, and file this Notice pursuant to
`
`Texas Civil Practice and Remedies Code 18.001.
`
`Defendants state the following counter-affidavits were served on Plaintiffs on July 24,
`
`2023:
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Valley
`Regional Medical Center pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Rio
`Grande Valley Interventional Pain pertaining to Plaintiff Betty Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Insight
`Diagnostics & Imaging pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at
`Singleton Associates PA pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Khit
`Chiropractic and Wellness Center pertaining to Plaintiff Betty Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Kay
`Medical Center pertaining to Plaintiff Betty Deleon, dated July 22, 2023;
`
`
`
`Electronically Filed
`8/23/2023 9:37 AM
`Hidalgo County District Clerks
`Reviewed By: Rubie Ortega
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Khit
`Chiropractic and Wellness Center pertaining to Plaintiff Marco Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Kay
`Medical Center pertaining to Plaintiff Marco Deleon, dated July 22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Rio
`Grande Valley Interventional Pain pertaining to Plaintiff Marco Deleon, dated July
`22, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Insight
`Diagnostics & Imaging pertaining to Plaintiff Marco Deleon, dated July 22, 2023;
`
`7.
`
`8.
`9.
`
`10.
`11.
`
`12.
`13.
`
`
`
`The following counter-affidavits were served on Plaintiffs on July 26, 2023:
`
`14.
`
`15.
`
`16.
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at
`Physicians Injury Clinic pertaining to Plaintiff Betty Deleon, dated July 26, 2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at
`Orthopedic Surgery Center pertaining to Plaintiff Betty Deleon, dated July 26,
`2023;
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at Dr.
`Jose Dones, MD, PA pertaining to Plaintiff Marco Deleon, dated July 26, 2023; and
`
`17.
`
`Counter-affidavit of Michelle Addison, CPC regarding services rendered at
`Orthopedic Surgery Center pertaining to Plaintiff Marco Deleon, dated July 26,
`2023;
`
`This notice of filing shall also serve as a supplemental response to all Requests for
`
`
`
`Disclosure and other discovery requests regarding medical and billing records.
`
`
`
`
`
`
`Dated: August 23, 2023
`
`
`Electronically Filed
`8/23/2023 9:37 AM
`Hidalgo County District Clerks
`Reviewed By: Rubie Ortega
`
`
`
`
`
`Respectfully submitted,
`
`MORGAN, LEWIS & BOCKIUS LLP
`
` /s/ Michelle D. Pector
`Michelle D. Pector
`State Bar No. 24027726
`michelle.pector@morganlewis.com
`Jared Wilkerson
`State Bar No. 24084096
`jared.wilkerson@morganlewis.com
`1000 Louisiana, Suite 4000
`Houston, Texas 77002
`(713) 890-5000 Telephone
`(713) 890-5001 Facsimile
`
`David G. Oliveria
`Roerig, Oliveira & Fisher, LLP
`State Bar No. 15254675
`doliveira@rofllp.com
`10225 N. 10th Street
`McAllen, Texas 78504
`(936) 393-6300 Telephone
`(936) 386-1625 Facsimile
`
`Attorneys for Space Exploration Technologies
`Corp.
`
`
`D. Alan Erwin
`Roerig, Oliveira & Fisher LLP
`10225 N. 10th Street
`McAllen, TX 78504
`aerwin@rofllp.com
`Tel.: 956.393.6300
`Fax: 956.386.1625
`
`Attorney for Defendant Ernesto Rosiles
`
`
`
`
`
`
`
`
`
`
`
`
`
`Electronically Filed
`8/23/2023 9:37 AM
`Hidalgo County District Clerks
`Reviewed By: Rubie Ortega
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on August 23, 2023, a true and correct copy of the foregoing document
`has been served electronically to all known counsel of record in accordance with the Texas Rules
`of Civil Procedure.
`
`
` /s/ Jared Wilkerson
`Jared Wilkerson
`
`
`
`
`
`
`
`
`
`
`
`
`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.
`Norma Orozco on behalf of Michelle Pector
`Bar No. 24027726
`norma.orozco@morganlewis.com
`Envelope ID: 78819601
`Filing Code Description: Notice
`Filing Description: Defendants' Notice of Service of Counter-affidavits
`Status as of 8/23/2023 1:13 PM CST
`
`Associated Case Party: Space Exploration Technologies Corp.
`
`Name
`Michelle Pector
`Jared Wilkerson
`
`BarNumber Email
`michelle.pector@morganlewis.com
`jared.wilkerson@morganlewis.com
`
`TimestampSubmitted
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`
`Status
`SENT
`SENT
`
`Case Contacts
`
`Name
`Norma Orozco
`Keith W.Lapeze
`TAYLOR SHIPMAN
`Kiara Campos
`Anita Malone
`
`BarNumber Email
`norma.orozco@morganlewis.com
`keith@lapezejohns.com
`taylor@lapezejohns.com
`kiara@lapezejohns.com
`records@lexitaslegal.com
`
`TimestampSubmitted
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`
`Status
`SENT
`SENT
`SENT
`SENT
`SENT
`
`Associated Case Party: ErnestoE.Rosiles
`
`Name
`D. Alan Erwin, Jr.
`Vilma Noyola
`Nancy Gonzalez
`
`BarNumber Email
`aerwin@rofllp.com
`vilman@rofllp.com
`nancyg@rofllp.com
`
`TimestampSubmitted
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`8/23/2023 9:37:55 AM
`
`Status
`SENT
`SENT
`SENT
`
`
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