Thomas

FACTS AND PROCEDURAL BACKGROUND

Plaintiff, a medical doctor, sued defendants alleging intentional interference with the right to practice his profession and unfair competition. The facts underlying the complaint are not relevant to the issues raised in this appeal. CHS and CMC specially appeared to move to quash the service of summons based on lack of personal jurisdiction. They also requested the court dismiss, or alternatively stay, the action based on the doctrine of forum non conveniens, arguing Texas was the proper forum for the case. St. Joseph Health System did not join those motions; it separately demurred to the complaint and moved to strike portions of it. At plaintiff’s request, and over defendants’ opposition, the court permitted jurisdictional discovery as to CHS and CMC. Plaintiff engaged in discovery with respect to the jurisdictional matters raised by defendants, with his counsel deposing five people. Two of the depositions took place in Texas and the other three in California. Defendants’ counsel traveled to each of the depositions from Los Angeles. After completing the depositions, plaintiff filed a written opposition to defendants’ motions. He argued the court…