Harris County Court

JT Chiro Sues a Sanctioned Texas Lawyer in Harris County Court. It Sure Reads Like Barratry

Under TX Disciplinary Rules, can I be disciplined if I pay someone not licensed to practice law to solicit clients for me or refer clients?

202235172

J&T CHIROPRACTIC PLLC

(AKA J&T CHIROPRACTIC LLC)

vs.

LAW OFFICE OF MERICK NEPOMUCENO P C

(DBA LAW OFFIC…

(Court 127, JUDGE RAVI K. SANDILL)

JUN 13, 2022 | REPUBLISHED BY LIT: JUN 13, 2022
MAY 4, 2023

Last visit/update

Feb 8, 2023: Defendants’ Motion to Consolidate or in the Alternative Motion to Abate

Feb 8, 2023: Defendants’ Motion to Consolidate or in the Alternative Motion to Abate

No movement in 102 days, since the first amended petition on Aug 1.

Where’s the dismiss for want of prosecution notice, Judge Sandill, the judge who blocks cases from public view – in violation of the First Amendment?

First Amended Petition

July 5; Citation Corporate (LAW OFFICE OF MERICK NEPOMUCENO PC)

Jun 30; Citation (EMMERICO TAN NEPOMUCENO AKA MERRICK NEPOMUCENO)

UPDATE: June 13, 2022

No movement on the docket since original petition filed.

Under the Texas Disciplinary Rules of Professional Conduct, can I be disciplined if I pay someone not licensed to practice law to solicit clients for me or to refer clients to me?

With certain very limited exceptions, the answer is yes. See Rule 7.03(b).

Also, see Rule 7.03(c) which prohibits payments to clients or anyone else in order to solicit employment.

Additionally, accepting referrals from certain Lawyer Referral Services is also prohibited. See 7.03(e).

Whatcha Reckon Shannon Lang, is it Barratry?

J&T Chiropractic, PLLC v. T&C Chiropractic, LLC

(4:22-cv-03285)

District Court, S.D. Texas

sep 26, 2022 | REPUBLISHED BY LIT: sep 28, 2022
MAY 4, 2023

Last visit/update

U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:22-cv-03285

J&T Chiropractic, PLLC v. T&C Chiropractic, LLC
Assigned to: Magistrate Judge Sam S Sheldon
Cause: 17:501 Copyright Infringement
Date Filed: 09/25/2022
Jury Demand: Defendant
Nature of Suit: 820 Copyright
Jurisdiction: Federal Question

 

Date Filed # Docket Text
03/15/2023 28 ANSWER to 1 Complaint with Jury Demand by Thy Ngoc Nguyen, T&C Chiropractic, LLC, filed. (Attachments: # 1 Exhibit Rule 7.7 Declaration, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B)(Bowen, James) (Entered: 03/15/2023)
03/17/2023 29 NOTICE re: 26 Minute Entry Order,,,, by Thy Ngoc Nguyen, T&C Chiropractic, LLC, filed. (Bowen, James) (Entered: 03/17/2023)

 


 

PACER Service Center
Transaction Receipt
05/04/2023 21:08:09

MINUTE ENTRY ORDER: The Court previously held a hearing on February 16, 2023 regarding Plaintiff’s motion to compel discovery (Dkt. No. 24). At that hearing, the Court also tentatively denied Defendant’s motion to dismiss and motion for more definite statement (Dkt. No. 13). For the reasons stated on the record, the Court now DENIES the motion (Dkt. No. 13). The Court further MODIFIES the Scheduling Orders as follows: Joint Pretrial Order is due August 14, 2023; Final Pretrial Conference is set for 10 a.m. on September 5, 2023; and Trial is set for 9 a.m. on September 11, 2023. (Signed by Magistrate Judge Sam S Sheldon)

U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:22-cv-03285

J&T Chiropractic, PLLC v. T&C Chiropractic, LLC
Assigned to: Magistrate Judge Sam S Sheldon
Cause: 17:501 Copyright Infringement
Date Filed: 09/25/2022
Jury Demand: None
Nature of Suit: 820 Copyright
Jurisdiction: Federal Question

 

Date Filed # Docket Text
02/09/2023 23 NOTICE of Setting as to 19 MOTION to Compel Discovery and Overrule Objections. Parties notified. Motion Hearing set for 2/16/2023 at 01:00 PM in by video before Magistrate Judge Sam S Sheldon, filed. (sjones, 4) (Entered: 02/09/2023)
02/21/2023 24 MINUTE ENTRY ORDER: The Court held a hearing by Zoom on Plaintiff’s Motion to Compel Discovery (Dkt. No. 19) on February 16, 2023. The Court ORDERED the parties to meet by Zoom and further meet-and-confer. The Court will hold a hearing by Zoom at 1 p.m. on February 27, 2023 to resolve any outstanding discovery disputes. Before the hearing, the parties shall file a joint document setting forth each remaining discovery dispute and each party’s position on such dispute. Appearances: Shannon Ashley Lang, James Warren Bowen. Ct Reporter: ERO. Digital Number: 12:59-1:18PM. (Signed by Magistrate Judge Sam S Sheldon) Parties notified.(sjones, 4) Modified on 2/21/2023 (sjones, 4). (Entered: 02/21/2023)
02/26/2023 25 REJOINDER to 19 MOTION to Compel Discovery and Overrule Objections Reflecting Each Party’s Position on Outstanding Issues, filed by J&T Chiropractic, PLLC. (Attachments: # 1 Defendants’ First Amended Responses and Objections to Plaintiff’s First Interrogatories, # 2 Defendants’ First Amended Responses and Objections to Plaintiff’s First Requests for Production)(Lang, Shannon) (Entered: 02/26/2023)
03/01/2023 26 MINUTE ENTRY ORDER: The Court held a hearing on Plaintiff’s motion to compel discovery responses (Dkt. No. 19) and rejoinder to motion to compel (Dkt. 25) on February 27, 2023. For the reasons stated on the record, the motion and rejoinder are GRANTED IN PART and DENIED IN PART. All objections, except for privileges, asserted by Defendant are overruled and stricken. Defendant shall amend their discovery responses and remove all objections. Defendant shall further provide supplemental responses by March 6, 2023 to Interrogatory No. 3 and Request for Production No. 6. Defendant shall continue to search for native documents and file a status report by March 20, 2023 if they cannot find them. The parties agreed to conduct depositions on April 5, 6 and 7, 2023. By March 31, 2023, the parties shall provide each other with any document that will be used in any way during these depositions. Appearances: Shannon Ashley Lang, James Warren Bowen. Ct Reporter: ERO. Digital Number: 12:58-1:13PM. (Signed by Magistrate Judge Sam S Sheldon) Parties notified.(sjones, 4) Modified on 3/1/2023 (sjones, 4). (Main Document 26 replaced on 3/1/2023) (sjones, 4). (Entered: 03/01/2023)
03/01/2023 27 MINUTE ENTRY ORDER: The Court previously held a hearing on February 16, 2023 regarding Plaintiff’s motion to compel discovery (Dkt. No. 24). At that hearing, the Court also tentatively denied Defendant’s motion to dismiss and motion for more definite statement (Dkt. No. 13). For the reasons stated on the record, the Court now DENIES the motion (Dkt. No. 13). The Court further MODIFIES the Scheduling Orders as follows: Joint Pretrial Order is due August 14, 2023; Final Pretrial Conference is set for 10 a.m. on September 5, 2023; and Trial is set for 9 a.m. on September 11, 2023. (Signed by Magistrate Judge Sam S Sheldon) Parties notified.(sjones, 4) Modified on 3/1/2023 (sjones, 4). Modified on 3/2/2023 (sjones, 4). (Main Document 27 replaced on 3/2/2023) (sjones, 4). (Entered: 03/01/2023)

 


 

PACER Service Center
Transaction Receipt
03/06/2023 20:05:52

Rejoinder

Definition;

A rejoinder is a response or reply to a statement or argument made by another person. It is often used in the context of a debate, discussion, or disagreement.

A rejoinder is typically a concise and focused statement that addresses the key points raised by the other person’s argument or statement, and may provide counterpoints or additional information to support one’s own position.

In general, a rejoinder is a way to continue a conversation or exchange of ideas by engaging with the points raised by the other person, and can help to clarify and deepen understanding of a particular topic.

Update Feb 11, 2023

She ain’t talkin’ to LIT about the appearance of barratry, instead she’s off filin’ a copyright infringement suit to keep the billin’ goin’ as the first case in Harris District Court pauses…for no good reason.

Rejoinder

Definition;

A rejoinder is a response or reply to a statement or argument made by another person. It is often used in the context of a debate, discussion, or disagreement.

A rejoinder is typically a concise and focused statement that addresses the key points raised by the other person’s argument or statement, and may provide counterpoints or additional information to support one’s own position.

In general, a rejoinder is a way to continue a conversation or exchange of ideas by engaging with the points raised by the other person, and can help to clarify and deepen understanding of a particular topic.

U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:22-cv-03285

Create an Alert for This Case on RECAP

J&T Chiropractic, PLLC v. T&C Chiropractic, LLC
Assigned to: Judge Andrew S Hanen
Cause: 17:501 Copyright Infringement
Date Filed: 09/25/2022
Jury Demand: None
Nature of Suit: 820 Copyright
Jurisdiction: Federal Question

 

Date Filed # Docket Text
10/09/2022 9 JOINT DISCOVERY/CASE MANAGEMENT PLAN by J&T Chiropractic, PLLC, filed.(Lang, Shannon) (Entered: 10/09/2022)
10/10/2022 10 RETURN of Service of SUMMONS Executed as to T&C Chiropractic, LLC served on 10/3/2022, answer due 10/24/2022, filed.(Lang, Shannon) (Entered: 10/10/2022)
10/10/2022 11 RETURN of Service of SUMMONS Executed as to Thy Ngoc Nguyen served on 10/3/2022, answer due 10/24/2022, filed.(Lang, Shannon) (Entered: 10/10/2022)
10/11/2022 12 NOTICE of Resetting. Parties notified. Initial Conference reset for 12/13/2022 at 10:50 AM in by video before Magistrate Judge Sam S Sheldon, filed. (sjones, 4) (Entered: 10/11/2022)
10/17/2022 13 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM and ( Motion Docket Date 11/7/2022.), MOTION for More Definite Statement by Thy Ngoc Nguyen, T&C Chiropractic, LLC, filed. (Attachments: # 1 Proposed Order Proposed order, # 2 Supplement Rule 7-1 certificate)(Bowen, James) (Entered: 10/17/2022)
11/07/2022 14 RESPONSE in Opposition to 13 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM and MOTION for More Definite Statement, filed by J&T Chiropractic, PLLC. (Attachments: # 1 Exhibit A: Infringed Work, # 2 Exhibit B: Infringing Work, # 3 Proposed Order)(Lang, Shannon) (Entered: 11/07/2022)
11/07/2022 15 REPLY to Response to 13 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM and MOTION for More Definite Statement, filed by Thy Ngoc Nguyen, T&C Chiropractic, LLC. (Bowen, James) (Entered: 11/07/2022)

 


 

PACER Service Center
Transaction Receipt
11/11/2022 21:41:00

U.S. District Court
SOUTHERN DISTRICT OF TEXAS (Houston)
CIVIL DOCKET FOR CASE #: 4:22-cv-03285

Create an Alert for This Case on RECAP

J&T Chiropractic, PLLC v. T&C Chiropractic, LLC
Assigned to: Judge Andrew S Hanen
Cause: 17:501 Copyright Infringement
Date Filed: 09/25/2022
Jury Demand: None
Nature of Suit: 820 Copyright
Jurisdiction: Federal Question
Plaintiff
J&T Chiropractic, PLLC
also known as
J&T Chiropractic, LLC
represented by Jessica Caitlin Hughes
Lang & Associates PLLC
1903 Vermont Street
Houston, TX 77019
832-479-9400
Fax: 832-479-9421
Email: jessica.hughes@shannonlanglaw.com
ATTORNEY TO BE NOTICEDShannon Ashley Lang
Lang & Associates PLLC
1903 Vermont Street
Houston, TX 77019
(832) 479-9400
Fax: 832-479-9421
Email: shannon.lang@shannonlanglaw.com
ATTORNEY TO BE NOTICED
V.
Defendant
T&C Chiropractic, LLC
formerly known as
T&C Chiropractic, PLLC
Defendant
Thy Ngoc Nguyen

 

Date Filed # Docket Text
09/26/2022 1 COMPLAINT against Thy Ngoc Nguyen, T&C Chiropractic, LLC f/k/a T&C Chiropractic, PLLC (Filing fee $ 402 receipt number ATXSDC-28829525) filed by J&T Chiropractic, PLLC a/k/a J&T Chiropractic, LLC. (Attachments: # 1 Exhibit)(Lang, Shannon) (Entered: 09/26/2022)
09/26/2022 2 Request for Issuance of Summons as to T&C Chiropractic, LLC f/k/a T&C Chiropractic, PLLC, filed.(Lang, Shannon) (Entered: 09/26/2022)
09/26/2022 3 Request for Issuance of Summons as to Thy Ngoc Nguyen, filed.(Lang, Shannon) (Entered: 09/26/2022)
09/26/2022 4 CERTIFICATE OF INTERESTED PARTIES by J&T Chiropractic, PLLC a/k/a J&T Chiropractic, LLC, filed.(Lang, Shannon) (Entered: 09/26/2022)
09/27/2022 5 NOTICE of Appearance by Jessica Hughes on behalf of J&T Chiropractic, PLLC a/k/a J&T Chiropractic, LLC, filed. (Hughes, Jessica) (Entered: 09/27/2022)
09/27/2022 6 Summons Issued as to Thy Ngoc Nguyen, T&C Chiropractic, LLC f/k/a T&C Chiropractic, PLLC. Issued summons delivered to plaintiff by NEF, filed. (Attachments: # 1 Summon)(hlerma, 4) (Entered: 09/27/2022)
09/27/2022 7 ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 10/20/2022 at 10:10 AM by video before Magistrate Judge Sam S Sheldon. (Signed by Judge Andrew S Hanen) Parties notified.(BrandisIsom, 4) (Entered: 09/27/2022)
09/27/2022 8 Register of Copyrights Notified. AO-121, filed. (BrandisIsom, 4) (Entered: 09/27/2022)

 


 

PACER Service Center
Transaction Receipt
09/28/2022 12:22:05

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JT Chiro Sues a Sanctioned Texas Lawyer in Harris County Court. It Sure Reads Like Barratry
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