, .
.
THE STATEOF TEXAS
exr
DR CHRISTINE ELLIS, DDS.
Plaint,
v.
ASDC HOLDINGS, LLC (ASDC), ALLSMILES DENTAL CE NTER, INC, ALLSMILES DENTAL PROFESSIONALS, PC,DR RICHARD MALOUF, DDS,LEWISVILLE SMILES, PLLC, STFRANCIS SMILES, PLLC, GARLANDROAD SMILES, PLLC, JACKSBOROSMILES, PLLC, JACKSBORO SMILESBY WIRE, PLLC, VALLEYVIEWSMILES, PLLC, PLANO MINY ARDSSMILES, PLLC, HALTOM CITY SMILES,PLLC, HALTOM CITY SMILES, PLLC
/a
ALL SMILES DENTAL
&
ORTHODONTICS, NORTHWESTHIGHWAY SMILES, PLLC, FORTWORTH SMILES BY WIRE, PLC,GARLAND ROAD SMILES BY WIE,PLLC, GARLAND ROAD SMILES PLLC,
/a
ALL SMILES DENTAL
&
ORTHODONTICS, S HAMPTONSMILES, PLLC, S HAMPTON SMILES,PLLC,
/a
ALL SMILES DENTAL
&
ORTHODONTICS, PARK PLAZA SMILES, PLLC,
d
PARK PLAZA SMILES, PLLC,
/a
ALL SMILESDENTAL
&
ORTHODONTICS
Defendants.
§
IN THE DISTRICT COURT OF
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Distr ict
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TAVIS COTY, TEXAS
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JUDICIAL DISTRICT
PLAINTIFFS' FIRST AMENDED PETITION
'
H JGhe tate of exas ("tate), by and through the ttoey General of exas, Greg bbott, brings this cause of action under the exas edicaid Fraud Prevention ct, (thect or "FP), EX HU.
Rs
ODE . chapter 36 he tate has primary responsibility for prosecuting this action under section 36.107(a) of the P. PrivatePerson Plaintiffelator r. hristine llis,... ("r. llis) is the elator in this case and as such is a named par Plaintiff. he ate and r. llis will be collectively referred to as"exas.he action from which this case was severed was led under seal on or about the 24 day of pri2012, by r. llis under section 36.102 ofthe P. n or aboutthe 25day of June 2012, the tate exercised its prerogative under section 36.104 of the P d formally led its otice ofnterention. n or about June 25,2012, the ourt granted leaveto exas to sever and unseal the claims against these efendants om the original case.
I.DISCOVERY CONTROL PLAN
1.1Plaintiffs designate this case as a evel 3 case requiring a discovery control plan tailored to the circumstances of this specic suit.
II.JURISDICTION
VENUE
Page2
.-
21his cour has subjectmatter jurisdiction over this case pursuant to section 36.052( d)of the P, which provides statutory remedies to redress the conduct of e efendants.he P provides authori for this action to be brought by the ttoey General and by r. llis. ex. Hum. es. ode§§ 36.052, 36.102.2.2his our has jurisdiction over each ofthe efendants named in this Petition becauseeach efendant does business in the tate of exas and committed the unlaw acts alleged in whole or in part in the tate2.3 enue is proper in ravis ounty under section 36.052(d) of the exas Human esources ode and additionally because many of the unawl acts committed by theefendants were committed iravis oun, including the maing ofthe false statementsand misrepresentations of material fact to the exas edicaid Program.
IIIPARTIESPLAINTIFFS
3.1Plaintiff
THE STATE OF TEXAS
represented by the toey General,
IS
authorized to bring this action under section 36.052 of the exas Human esources ode.3.2 elator
I
Paintiff
DR CHRISTINE ELLIS, DDS, MSD,
is an individualauthorized to bring this action under section 36.102 of the exas Human esources ode.
DEFENDANTS
3.3efendant
ASDC HOLDINGS, LLC (ASDC)
is a eaware limited liabilicompany doing business in the tate of exas. ts principal place of business is 200 outh
Pae3
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