Court Filings
Data license: Public court records
1 row where doc_type = "LTR" and party = "Kassab" sorted by date descending
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| filing_id | date ▲ | doc_type | party | description | doc_type_detail | procedural_posture | chain | outcome | phase | filename | relief_requested | full_text |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 61 | 2023-09-20 | LTR | Kassab | Letter to judge re final judgment | Kassab's letter brief to Judge Christine Weems responding to Pohl's Reply filed the night before the hearing on entry of final judgment, addressing new arguments on exemplary damages, attorneys' fees, TUTSA preemption of conspiracy, and Precision's exoneration | Post-hearing letter brief filed September 20, 2023 in the 281st Judicial District Court, Harris County, Cause No. 2018-58419. Addressed to Judge Christine Weems. Pohl's Reply was filed well after working hours the evening of September 18, 2023 — the night before the September 19, 2023 hearing on entry of final judgment. This letter responds to new arguments and authorities raised in that Reply. Written by Kevin Dubose (Alexander Dubose & Jefferson LLP, Board Certified Civil Appellate Law). | JDGMT-1 | N/A | Phase 5 | 2023-09-20_LTR_Kassab-Letter-to-Judge-re-Final-Judgment_FILED.pdf | That the Court refrain from signing Pohl's proposed final judgment and sustain Kassab's objections | 9/20/2023 3:18 PM Kevin Dubose Marilyn Burgess - D18is4tr4ic Ht aCrlvearkr dH Satrrreise Ct ounty kdubose@ adjtlaw.com Houston, TEenxvaes lo7p7e0 0N8o-.4 7394726 5300 By: Bonnie Lugo (713) 523-0667 www.adjtlaw.com Filed: 9/20/2023 3:18 PM Board Certified Civil Appellate Law September 20, 2023 The Honorable Christine Weems Judge 281st District Court 201 Caroline, 14th Floor Houston, Texas 77002 Re: Cause No. 2018-58419; Michael A. Pohl, and Law Otffice of Michael A. Pohl, PLLC v. Lance Christopher Kassab and Lanrcie Christopher Kassab, P.C. D/B/A The Kassab Law Firm s Dear Judge Weems: s Pohl’s response to Kassab’s objections to the gproposed judgment were filed well after working hours the night before the hearing orn entry of judgment. Because that response raised some new arguments and authoriBties that Kassab has not had a chance to address, we file the following letter brief to addnress some of those new matters. A. Exemplary damages are not rercoverable because Question 17 was not answered unanimously. M Pohl relies on several cases noot previously addressed, and all are distinguishable for important reasons. e • Bruce v. Oscar Renda Cofntracting, 657 S.W.3d 453, 464 (Tex. App.—El Paso 2022, pet. filed). In Bruce there was no Additional Certificate in which the jury was instructed to certify whether certain jury questions were unanimous. Id. at 463. In the present case, there was an Additionaol Certificate in which the jury failed to certify that Question 17 was unanimous. C • Stover v. ADM Milling Co., No. 05-17-00778-CV, 2018 Tex. App. LEXIS 10883 (Tex. App.—Dallas Dec. 28, 2018, pet. denied) (mem. op.). In Stover there was an Additional Certificfate, and the jury certified that the predicate question for exemplary damages (Qunestions 15 and 16 on fraud and malice) were answered unanimously. Id. at *12. In the prUesent case, the equivalent predicate question (Question 17 on willful and malicious misappropriation) was not certified as unanimous. • Bryan v. Papalia, 542 S.W.3d 676, 692–93 (Tex. App.—Houston … |
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CREATE TABLE filings (
filing_id INTEGER PRIMARY KEY,
date TEXT,
doc_type TEXT,
party TEXT,
description TEXT,
doc_type_detail TEXT,
procedural_posture TEXT,
chain TEXT,
outcome TEXT,
phase TEXT,
filename TEXT,
relief_requested TEXT,
full_text TEXT
);