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3 rows where doc_type = "LTR" and phase = "Phase 5" 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 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 63 | 2023-10-23 | LTR | Pohl | Request for ruling on final judgment | Pohl's Request for a Ruling on Motion for Entry of Final Judgment, urging Court to expedite consideration of the pending motion and raising concerns about Kassab's continued harassment through Mississippi bar complaints filed using case materials | Request for ruling filed October 23, 2023, more than one month after the September 19, 2023 hearing on entry of judgment. The Motion for Entry of Final Judgment was filed promptly after the August 31, 2023 jury verdict and has been ripe for over a month without a ruling. | JDGMT-1 | N/A | Phase 5 | 2023-10-23_LTR_Pohl-Request-for-Ruling-on-Final-Judgment_FILED.pdf | That the Court expedite consideration and grant Pohl's Motion for Entry of Final Judgment, entering final judgment in Pohl's favor in the form attached to the Motion | 10/23/2023 5:36 PM Marilyn Burgess - District Clerk Harris County Envelope No. 80886597 By: Patricia Gonzalez Filed: 10/23/2023 5:36 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et. al § IN THE DISTRICT COURT OF Plaintiffs, § V. § HARRIS COUNTY,k TEXAS § e LANCE CHRISTOPHER § C l KASSAB, et. al § § c Defendants. § 281ST JUDrICIAL DISTRICT POHL’S REQUEST FOR A RULING ON POHL’S MOTION FOR ENTRY OF FINAsL JUDGMENT Pohl requests that the Court expedite its consideration of Pohl’s Motion for Entry of Final Judgment (the “Motion”). The Motion has been ripe for a ruling for over a month, and while Pohl waits for entry of judgment on the jury verdict in his favor, it appears that Kassab is using materials from this lawsuit to continue to harass Pohl—adespite the jury’s verdict being inconsistent with Kassab’s barratry and unauthorized practice of law theories in this case. The Court should promptly enter a final judgment to gieve finality to the trial proceedings in this case. f I. BACKGROUND Kassab has unsucceyssfully accused Pohl of engaging in barratry and the unauthorized practice of law for the lCast six years. According to Kassab, Pohl allegedly obtained clients through barratry and the unaauthorized practice of law in Mississippi, and thus, Pohl did not have rightful, legal, or equitabfle title in any trade secret concerning Pohl’s clients. However, on August 31, 2023, theU jury rendered a verdict in Pohl’s favor, and found that, despite Kassab’s allegations of barratry and the unauthorized practice of law, Pohl owned the trade secrets concerning his clients. After the jury rendered their verdict, Pohl promptly filed the Motion requesting entry of judgment and set the Motion for a hearing on September 19, 2023. As the briefing and arguments at that hearing showed, Pohl is entitled to entry of a final judgment in his favor that gives effect to the jury’s findings of liability and damages. Since trial, Pohl has learned new information that suggests that Kassab is using materials from this case to continue to harass P… |
| 62 | 2023-09-22 | LTR | Pohl | Response to Kassab letter | Pohl's letter to Judge Christine Weems replying to Kassab's September 20, 2023 post-hearing letter brief, addressing exemplary damages burden of proof, recoverability of attorneys' fees, conspiracy preemption, and Precision's exoneration | Sur-reply letter brief filed September 22, 2023 in the 281st Judicial District Court, Harris County, Cause No. 2018-58419. Addressed to Judge Christine Weems. Filed two days after Kassab's post-hearing letter brief (September 20) and three days after the September 19 hearing on entry of judgment. Pohl notes his Reply was filed one business day after Kassab's Response. Signed by Harris Y. Wells and Jean C. Frizzell of Reynolds Frizzell LLP. | JDGMT-1 | N/A | Phase 5 | 2023-09-22_LTR_Pohl-Response-to-Kassab-Letter-re-Final-Judgment_FILED.pdf | That the Court grant Pohl's Motion, enter judgment in the form attached as Exhibit B to the Motion, and overrule Kassab's objections to entry of judgment | 9/22/2023 9:53 PM Marilyn Burgess - District Clerk Harris County Envelope No. 79868932 By: Bonnie Lugo Filed: 9/22/2023 9:53 PM September 22, 2023 Via Electronic Filing Judge Christine Weems r Harris County Civil Courthouse l 201 Caroline, 14th Floor Houston, Texas 77002 c t RE: Michael A. Pohl et al. v. Lance Christopher Kassab et al.; Casutse No. 2018-58419; In the 281st Judicial District Court of Harris County, Texas. D i Reply to Kassab’s Post-Hearing Letter on Pohl’s Motion for Entry of Judgment (the “Motion”) Dear Judge Weems: e In Kassab’s September 20, 2023 letter (the “Leutter”), Kassab suggests that the timing of Pohl’s Reply brief entitles Kassab to further briefing. Pohl filed his Reply one business day after Kassab filed his Response. Because Kassab misstates both the law and facts in the Letter, Pohl files this reply letter. l DMISCUSSION A. The Jury Verdict shows thoe Jury unanimously awarded exemplary damages. Kassab makes two argumencts on the recovery of exemplary damages: he claims (1) it was Pohl’s burden to ensure the Jury fsigned a certificate of unanimity for Question 17, and (2) that various cases Pohl cited are “distinguishable for important reasons.” Letter at 1–2. Each argument fails. First, as the Supreme Cyourt of Texas held in USAA Tex. Lloyds Co. v. Menchaca, “the party who must rely on theo conflicting answer to avoid the effect of answers that establish liability . . . bore the burden to object.” 545 S.W.3d 479, 519 (Tex. 2018) (emphasis added). That is Kassab here. lSecond, any so-called distinguishing facts either are not distinguishing or are immaterial becaucsei the reasoning of those cases, applied to the facts of this case, shows Pohl is entitled to an awfard of exemplary damages. 1. It was Kassab’s burden to object because he seeks to set aside the Jury’s answers. Pohl obtained the necessary findings to support an award of exemplary damages against Kassab through the Jury’s answers to Questions 2, 17, and 19.1 Kassab asks the Court to ignore the Jury’s findings because he … |
| 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
);