Minu RX, Ltd. D/B/A Memorial Compounding Pharmacy Minu GP, LLC v. Avant Medical Group, P.A. D/B/A Interventional Spine Associates, and Brett L. Garner D/B/A Allied Medical Centers, 14-15-00378-CV

Background

Appellants (Khyati Undavia, Minu RX, Ltd., MINU GP, LLC) filed a petition for permissive interlocutory appeal from a Harris County trial-court matter involving a mutual release executed by several signatories.
Appellees (Avant Medical Group, P.A.; Brett L. Garner d/b/a Allied Medical Centers; others) argued the release does not bind them because of disputed facts about agent–principal relationships and agency authorization.
Appellants contend the controlling legal question is whether an unnamed party that falls within broadly enumerated categories in a release (e.g., officers, agents, employees) is bound as a matter of law when it is sufficiently "connected" to the signatory and the subject matter of the release.
Appellants rely on prior Texas appellate decisions that applied a "connection" test to extend releases to unnamed defendants without probing agency fact issues, arguing the same principle should apply to unnamed plaintiffs.
Factual points emphasized by Appellants: Avant procured rental insurance for Sterling (a release signatory); Avant occupied Sterling’s rented space; Sterling managed Avant’s non-medical business dealings; Garner is an officer of Sterling and Nisal (both signatories), showing an "intimate relationship" or connection.
Appellants request the Fourteenth Court of Appeals grant permissive interlocutory review, arguing the legal question can be resolved as a matter of law and that an immediate appeal would materially advance termination of the litigation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held (Appellants' Position)
Whether an unnamed plaintiff encompassed by broad release categories is bound by the release	The unnamed plaintiff is bound if it falls within the enumerated categories and is connected to the signatory/subject matter	Release cannot bind unnamed parties absent proof of agency/express authorization; disputed facts preclude summary resolution	Appellants: the question is one of law—apply the "connection" test and bind the unnamed plaintiff as matter of law; seek permissive appeal
Whether resolving the issue requires probing agency fact questions	Plaintiff: no — precedent extends releases to unnamed parties without detailed agency inquiry	Defendant: yes — agency scope and express authorization are factual matters for the jury	Appellants: precedent avoids agency fact inquiries; courts decide connection as matter of law
Whether established precedent supports extending releases to unnamed plaintiffs (not just unnamed defendants)	Plaintiff: courts have applied releases to unnamed defendants via "connection" test; same logic should apply to unnamed plaintiffs	Defendant: distinguished — those cases involved unnamed defendants and do not control here	Appellants: precedent and policy (finality) support treating unnamed plaintiffs similarly
Whether permissive interlocutory appeal would materially advance termination	Plaintiff: yes — a favorable ruling would allow final summary judgment and end litigation	Defendant: no — factual disputes remain so appeal would not dispose of the case	Appellants: appellate resolution of the legal question would dispose of the release issue and materially advance termination

Key Cases Cited

Winkler v. Kirkwood Atrium Office Park, 816 S.W.2d 111 (Tex. App.—Houston [14th] 1991) (affirming summary judgment by applying a "connection" test to extend a release to unnamed parties without detailed agency inquiry)
Vera v. North Star Dodge Sales, Inc., 989 S.W.2d 13 (Tex. App.—San Antonio 1998) (applying a connection analysis to hold that a release of a corporation also released employees associated with the transaction)
Dyrcz v. Graham Bros. of Longview, LLC, 234 Fed. Appx. 236 (5th Cir. 2007) (affirming district-court application of a connection-based analysis to extend a release to related entities/employees)