costs of such action so incurred, including, without limitation, reasonable attorney’s fees and applicable court costs.
Ex. A at § F.3. Additionally, Hospital is entitled to recover its reasonable and necessary attorney’s fees under Chapter 38 of the TEXAS CIVIL DEFENDANTS & REMEDIES CODE.
VII. CONDITIONS PRECEDENT AND RULE 193.7 NOTICE
26. Pursuant to TEX. R. CIV. P. 54, all conditions precedent to Hospital’s claims for relief have been performed or have occurred.
27. Pursuant to TEX. R. CIV. P. 193.7, Hospital hereby gives notice to Defendant that Hospital intends to use all documents exchanged and produced between the parties (including, but not limited to, correspondence, pleadings, records, and discovery responses) during the trial of this matter.
VIII. …show more content…
PRAYER
WHEREFORE, Plaintiff Weatherford Texas Hospital Company, LLC d/b/a Weatherford Regional Medical Center respectfully requests that Defendant Joseph Daniels, D.O. d/b/a Southwest Orthopedics Associates be cited to answer and appear herein, and, upon final hearing, that the Court enter judgment against Defendant and in Hospital’s favor in the amount of $57,709.68 plus pre judgment and post judgment interest at the highest rate allowed by law, and Hospital’s reasonable costs and attorney’s fees incurred in this action. The Hospital further requests all other relief, both special and general, at law and/or in equity, to which it shows itself justly
Ex. A at § F.3. Additionally, Hospital is entitled to recover its reasonable and necessary attorney’s fees under Chapter 38 of the TEXAS CIVIL DEFENDANTS & REMEDIES CODE.
VII. CONDITIONS PRECEDENT AND RULE 193.7 NOTICE
26. Pursuant to TEX. R. CIV. P. 54, all conditions precedent to Hospital’s claims for relief have been performed or have occurred.
27. Pursuant to TEX. R. CIV. P. 193.7, Hospital hereby gives notice to Defendant that Hospital intends to use all documents exchanged and produced between the parties (including, but not limited to, correspondence, pleadings, records, and discovery responses) during the trial of this matter.
VIII. …show more content…
PRAYER
WHEREFORE, Plaintiff Weatherford Texas Hospital Company, LLC d/b/a Weatherford Regional Medical Center respectfully requests that Defendant Joseph Daniels, D.O. d/b/a Southwest Orthopedics Associates be cited to answer and appear herein, and, upon final hearing, that the Court enter judgment against Defendant and in Hospital’s favor in the amount of $57,709.68 plus pre judgment and post judgment interest at the highest rate allowed by law, and Hospital’s reasonable costs and attorney’s fees incurred in this action. The Hospital further requests all other relief, both special and general, at law and/or in equity, to which it shows itself justly