289001125v.1 

289001125v.1

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION 

CHRISTINE LITTLE 

Plaintiff, 

v. 

INMODE, LTD., INMODE MD, LTD., 

and INVASIX, INC., 

Defendants. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§

 §

CIVIL ACTION NO. 4-23-CV-00332-ALM

DEFENDANT INVASIX INC.’S FIRST AMENDED DISCLOSURES 

Defendant Invasix, Inc. (“Invasix”), by and through its attorneys, Claire Parsons of Wilson 

Elser Moskowitz Edelman & Dicker, and Angela L. Angotti and Paige L. Cheung of BOWMAN AND 

BROOKE LLP, hereby submits its first amended disclosures pursuant to Rule 26(a)(1)(A) of the Federal 

Rules of Civil Procedures. 

By making the following amended disclosures, Invasix does not represent that it is identifying 

every witness or document possibly relevant to this action. Invasix reserves the right to object to 

discovery on the basis of privilege, work product, relevance, undue burden, or any other valid 

objections, or to object to any other discovery request or proceeding which involves or relates to the 

subject matter of these disclosures. Invasix also does not waive its right to object to the admission at 

trial of any document, tangible thing, or related testimony under the Federal Rules of Evidence. Invasix 

reserves the right to call any witness or present any exhibit or item at trial not listed but determined 

through discovery or investigation to be relevant to the subject matter of this action. These initial 

disclosures represent Invasix’s good faith effort to identify individuals or information that it is aware 

of at this time to support its defenses. 

At this time, Invasix’s Rule 12(b)(6) Motion to Dismiss Plaintiff’s First Amended Complaint 

is currently pending in front of the Court. Accordingly, it is not known what claims, if any, will remain 

after the Court’s ruling. Further, Invasix has not yet filed its Answer, and its discovery, investigation, 

and preparation for trial are ongoing. Invasix reserves the right to amend, supplement, or revise its 

disclosures as provided in Rule 26(e)—either through express supplements or through responses to 

formal discovery responses—after the Court’s ruling on the pending Motion, or as Plaintiff provides 

additional information further disclosing the nature of her allegations, amends her pleadings, or 

otherwise. All of the disclosures set forth below are made subject to the above qualifications and 

reservations of rights. 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 1 of 9 PageID #: 808
289001125v.1 

289001125v.1

A. The Correct Names of the Parties to the Action: 

Pursuant to the Order Governing Proceedings (Dkt. #22, p. 4) and based on the pleadings on 

file, Invasix understands the correct party names to be: 

Plaintiff: Christine Little

Defendants: Invasix, Inc.

InMode Ltd. 

InMode MD Ltd. 

B. The Name, Address, and Telephone Number of Any Potential Parties to the Action: 

Pursuant to the Order Governing Proceedings (Dkt. #22, p. 4) and based upon information 

and belief, Le Beau Visage Medical Spa, LLC, Jason M. Riehs, MD, and Dedra Gleason are known to 

Invasix as participating in the event described in Plaintiff’s First Amended Complaint. Invasix does 

not have the address or phone number of the above individuals, and the address and phone number 

of Le Beau Visage is already known to Plaintiff and equally available to Plaintiff at this link: 

https://lebeauvisagemedicalspa.com/. 

C. Individuals Likely to Have Discoverable Information that Invasix May Use to Support 

its Defenses: 

Pursuant to Fed. R. Civ. P. 26(a)(1)(A)(i), Local Rule CV-26(d), and the requirements set forth by 

the Order Governing Proceedings (Dkt. #22), Invasix identifies the following individuals who are likely 

to have discoverable information relating to the issues, a brief characterization of their connection to the 

case, and a fair summary of the substance of the information known by such person: 

RESPONSE: 

1. Plaintiff Christine Little 

c/o Stephen Higdon, Michael Lyons, and Michael Fechner 

LYON & SIMMONS, LLP 

2101 Cedar Springs Road 

Suite 1900 

Dallas, Texas 75201 

(214) 665-6900 

Subject of Information: As the plaintiff in this matter, Ms. Little is expected to have

discoverable knowledge of the incident, injuries, and damages as stated in the First 

Amended Complaint. 

2. Corporate representative of Invasix, Inc. 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 2 of 9 PageID #: 809
289001125v.1 

289001125v.1

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Invasix’s corporate representative is expected to have 

discoverable knowledge pertaining to Plaintiff’s claims regarding the Evoke in the First 

Amended Complaint.

3. Corporate representative of InMode Ltd. 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: InMode Ltd.’s corporate representative is expected to have

discoverable information pertaining to Plaintiff’s claims regarding the Evoke in the First 

Amended Complaint and in support of InMode Ltd.’s jurisdictional arguments. 

4. Corporate representative of InMode MD Ltd. 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: InMode MD Ltd.’s corporate representative is expected to have

discoverable information pertaining to the responses in support of InMode MD Ltd.’s and 

jurisdictional arguments. 

5. Maureen Abdulla 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 3 of 9 PageID #: 810
289001125v.1 

289001125v.1

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Ms. Abdulla is a clinical administrator who received the adverse

event report pertaining to the incident made the basis for this lawsuit. She is expected to 

have discoverable information pertaining to the incident and Plaintiff’s injury as alleged in 

the First Amended Complaint. 

6. Dr. Jason M. Riehs 

3685 Preston Road, Suite 129 

Frisco, Texas 75034 

(214) 856-8447 

Subject of Information: Dr. Riehs owns the clinic where Plaintiff was treated with the

Evoke device. He is expected to have discoverable information relating to the incident, 

the functionality of the device, Plaintiff’s marketing defect claim, and Plaintiff’s injury and 

damages as alleged in the First Amended Complaint. 

7. Le Beau Visage Medical Spa, LLC 

3685 Preston Road, Suite 129 

Frisco, Texas 75034 

(214) 856-8447 

Subject of Information: As the incident took place at Le Beau Visage Medical Spa, the 

company is expected to have discoverable information relating to Plaintiff’s claims in the 

First Amended Complaint pertaining to the incident, injury, and damages.

8. Dedra Gleason 

3685 Preston Road, Suite 129 

Frisco, Texas 75034 

(214) 856-8447 

Subject of Information: Upon information and belief, Ms. Gleason was the esthetician

who treated Plaintiff with the Evoke device. She is expected to have discoverable 

information relating to the incident, Plaintiff’s marketing defect claim, and Plaintiff’s injury 

and damages as set forth in the First Amended Complaint. 

9. Employees of Le Beau Visage Medical Spa, LLC 

3685 Preston Road, Suite 129 

Frisco, Texas 75034 

(214) 856-8447 

Subject of Information: As the incident took place at Le Beau Visage Medical Spa, the

company’s employees are expected to have discoverable information relating to Plaintiff’s 

claims in the First Amended Complaint pertaining to the incident, injury, damages, and 

marketing defect claim. 

10. Unknown physicians and other healthcare providers 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 4 of 9 PageID #: 811
289001125v.1 

289001125v.1

Subject of Information: Physicians and other medical personnel who treated Plaintiff 

before or after the alleged events giving rise to this lawsuit may have knowledge about 

any prior treatments and Plaintiff’s alleged injury and damages. 

11. Holly Scaff 

c/o Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Ms. Scaff is a Clinical Manager who provided post-incident

training for Dr. Riehs’ staff on August 4, 2021. She is expected to have discoverable 

information relating to Plaintiff’s marketing defect claim. 

12. Lori Sheffield, RN 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Ms. Sheffield is an Independent Training Consultant who

provided training to Dr. Riehs and his staff on March 16, 2021 for the Evoke device. She 

is expected to have discoverable information relating to Plaintiff’s marketing defect claim. 

13. Miguel Lupercio

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Mr. Lupercio is a Senior Service Technician who conducted

post-incident testing in the United States upon the Evoke device at issue in this case. He 

is expected to have discoverable information relating to Plaintiff’s manufacturing defect 

claim. 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 5 of 9 PageID #: 812
289001125v.1 

289001125v.1

14. Lance Baird 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Mr. Baird was a District Sales Manager at the time of the sale of

the Evoke to Dr. Riehs and is now a Regional Sales Director. He is expected to have 

discoverable knowledge regarding the sale of the Evoke to Dr. Riehs. 

15. Dr. Michael Kreindel 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Dr. Kreindel is expected to have discoverable knowledge

regarding the design of the Evoke. 

16. A corporate representative with knowledge regarding the design, manufacture, testing, or 

marketing of the Evoke device. 

c/o Claire W. Parsons 

WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2039 

and 

Angela L. Angotti and Paige L. Cheung 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

Subject of Information: Invasix and/or InMode LTD will designate a corporate 

representative who is expected to have discoverable knowledge regarding the design, 

manufacture, testing, or marketing of the Evoke device. 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 6 of 9 PageID #: 813
289001125v.1 

289001125v.1

17. Any and all persons named in Plaintiff’s Rule 26 Initial Disclosures and amendments 

thereto. 

Invasix specifically reserves the right to amend, modify, or supplement this disclosure as 

additional facts are ascertained. 

D. Documents, Electronically Stored Information, and Tangible Things: 

Pursuant to Fed. R. Civ. P. 26(a)(1)(A)(ii) and the requirements set forth by the Order 

Governing Proceedings (Dkt. #22 p. 4), Invasix identifies the following categories of documents, data 

compilations, and tangible things that may be used to support Invasix’s claims or defenses, other than 

information that would be used solely for impeachment, and that are currently in the possession, 

custody, or control of Invasix. Invasix has also produced documents, that may be used to support its 

claims or defenses. Nothing in this paragraph should be construed as an admission that any particular 

document, data compilation, or tangible thing identified in these Initial Disclosures is in fact relevant 

to the claim or defense of any party to these proceedings: 

1. The Evoke device at issue in this case. 

Location: Israel

2. Information and documents regarding Plaintiff’s medical and billing records as 

they pertain to the incident, injury, and damages set forth in the First Amended 

Complaint. 

Location: Plaintiff. 

3. Information and documents regarding Plaintiff’s alleged economic loss as set forth 

in the First Amended Complaint. 

Location: Plaintiff 

4. Information and documents relating to the incident at Le Beau Visage Medical 

Spa. 

Location: Plaintiff; Dr. Riehs; Le Beau Visage Medical Spa. 

Invasix also refers Plaintiff to the documents produced pursuant to these disclosures. 

5. Information and documents regarding the design, manufacture, testing, and sale 

of the Evoke device at issue in this case to the extent necessary to oppose Plaintiff’s 

claims in the First Amended Complaint. 

Location: InMode, Ltd. has information regarding the design, manufacture, and final 

testing of the Evoke device at issue. Invasix has information regarding the testing done 

in the United States and the sale of the Evoke device at issue. 

6. All documents and materials sold with the Evoke device at issue in this case at its 

time of purchase on or about December 30, 2020, by Dr. Riehs, including but not 

limited to the manual for the Evoke device. 

Location: Invasix Inc. 

Invasix also refers Plaintiff to the documents previously produced with Invasix’s initial 

disclosures. 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 7 of 9 PageID #: 814
289001125v.1 

289001125v.1

7. Any advertising/marketing materials as they pertain to the Evoke device as alleged 

in the First Amended Complaint. 

Location: Invasix Inc; Dr. Riehs. 

Invasix also refers Plaintiff to the documents previously produced with Invasix’s initial 

disclosures. 

8. Any adverse medical device reports as they pertain to the Evoke device and 

submitted to the Food and Drug Administration. 

Location: Publicly available. 

9. Documents and information relating to the results of the investigation as they 

pertain to the Evoke device and the incident made the basis for the lawsuit.

Location: Invasix, Inc. 

Invasix also refers Plaintiff to the documents previously produced pursuant with 

Invasix’s initial disclosures. 

10. Documents and information identified by Plaintiff in her Rule 26 Initial 

Disclosures. 

11. Documents identified through discovery in this case. 

E. Damages: 

Pursuant to Fed. R. Civ. P. 26(a)(1)(A)(iii), Invasix has no claim for damages against Plaintiff 

at this time aside from recovery of its attorneys’ fees and costs. Invasix reserves the right to seek 

damages. 

F. Insurance: 

Pursuant to Fed. R. Civ. P. 26(a)(1)(A)(iv), Invasix refers Plaintiff to the declarations page 

previously produced with Invasix’s initial disclosures. 

G. Authorizations Described in Local Rule CV-34: 

Not applicable to Invasix.

H. Reservation of Rights 

Invasix specifically reserves the right to amend, modify, and supplement these Initial 

Disclosures as additional facts are ascertained, analyses made, legal research completed, expert 

opinions exchanged, and contentions formulated, including, but not limited to, the identification of 

individuals, identification of additional documents and materials if such information comes to their 

attention through further investigation, discovery, or otherwise. 

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 8 of 9 PageID #: 815
289001125v.1 

289001125v.1

Respectfully submitted, 

/s/ Claire W. Parsons 

Claire Parsons 

State Bar No. 24051159 

Claire.Parsons@wilsonelser.com 

WILSON, ELSER, MOSKOWITZ, 

EDELMAN & DICKER, LLP 

909 Fannin Street, Suite 3300 

Houston, Texas 77010 

(713) 353-2000 

(713) 785-7780 Facsimile 

ANGELA L. ANGOTTI 

State Bar No. 24112893 

/s/ Paige L. Cheung

PAIGE L. CHEUNG 

State Bar No. 24116193 

BOWMAN AND BROOKE LLP 

2901 Via Fortuna Drive, Suite 500 

Austin, Texas 78746 

(512) 874-3836 

(512) 874-3801 (Fax) 

angela.angotti@bowmanandbrooke.com 

paige.cheung@bowmanandbrooke.com 

Counsel for Defendants 

CERTIFICATE OF SERVICE 

I do hereby certify that on November 1, 2023, a true and correct copy of the foregoing 

document was served upon all known counsel of record in this cause via electronic mail in accordance 

with the Federal Rules of Civil Procedure and Local Rule CV-5(c). 

Michael P. Lyons: mlyons@lyons-simmons.com 

P. Wes Black: wblack@lyons-simmons.com 

Stephen Higdon:shigdon@lyon-simmons.com 

Michael S. Fechner, Jr.

mfechner@lyons-simmons.com 

LYONS & SIMMONS, LLP

2101 Cedar Springs Road, Suite 1900 

Dallas, Texas 75201 

(214) 665-6900 

(214) 665-6950 (Fax) 

Counsel for Plaintiff Christine Little 

/s/Claire W. Parsons

Claire W. Parsons

Case 4:23-cv-00332-ALM Document 48-3 Filed 11/02/23 Page 9 of 9 PageID #: 816