Court Filings
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5 rows where doc_type = "OA" and phase = "Phase 1" 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 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 12 | 2018-11-07 | OA | Kassab | 3rd Amended Answer | Kassab's Third Amended Answer, Affirmative Defenses, Counterclaim, and Designation of Responsible Third Parties | Filed November 7, 2018 in Cause No. 2018-58419, 189th Judicial District Court, Harris County, Texas. The day after the Second Amended Answer. Third amended responsive pleading, further expanding counterclaims from 235 to 242 assigned barratry claimants. Adds additional detail to the Designation of Responsible Third Parties section regarding Shepherd's knowledge of Favre's document transfers to third parties prior to the Federal Litigation settlement. | PLEAD-1 | N/A | Phase 1 | 2018-11-07_OA_Kassab-3rd-Amended-Answer-CC_FILED.pdf | Plaintiffs take nothing; Kassab recovers on counterclaims and against third-party defendants including actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other just relief | 11/7/2018 4:22 PM Chris Daniel - District Clerk Harris County Envelope No. 28873961 By: ARIONNE MCNEAL Filed: 11/7/2018 4:22 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIrAL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LANCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S THIRD AMENDED ANSWER, AFFIRMATIVE DEFENSES AND COUNtTERCLAIM, AND DESIGNATION OF RESPONSIBLE THIRD PARTIES TO THE HONORABLE JUDGE OF SAID COURT: s COMES NOW, Defendants, Lance Christopher Kgassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm and files this thBeir Third Amended Answer, Affirmative Defenses, and Counterclaim, and Designation of Ryesponsible Third Parties, and would respectfully show the Court as follows; a RULfE 47 STATEMENT The Kassab Defendants, in teheir capacity as Counter-Plaintiffs, seek monetary relief of more than $1,000,000.00. f y PARTIES Plaintiff, Michael A. Pohl is an individual lawyer residing in Colorado. Plaintiff, Laawl Offices of Michael A. Pohl is a law firm set up for the practice of law in various states of ithe union, including Texas. Defnendant, Scott Favre is a nonresident individual residing in Mississippi. Defendant, Scott M. Favre, PA, LLC is a nonresident limited liability company located in Mississippi. Defendant, Precision Marketing Group, LLC is a nonresident limited liability company located in Mississippi. Defendant, F. Douglas Montague III is a nonresident individual residing in Mississippi. Defendant, Montague, Pittman & Varnado, PA is a nonresident professional association located in Mississippi. Defendant, Tina Nicholson is an individual residing in Texas. k Defendant, Baker Nicholson, LLP, d/b/a Baker Nicholson Law Firm ils a limited liability partnership located in Texas. c Defendant, Counter-Plaintiff, Lance Christopher Kassab is an sindividual residing in Texas. Defendant, Counter-Plaintiff, Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm is a professional corporation … |
| 11 | 2018-11-06 | OA | Kassab | 2nd Amended Answer | Kassab's Second Amended Answer, Affirmative Defenses, Counterclaim, and Designation of Responsible Third Parties | Filed November 6, 2018 in Cause No. 2018-58419, 189th Judicial District Court, Harris County, Texas. The day after the reply brief on the TCPA motion. This is the second amended responsive pleading, expanding the counterclaims from 150 to 235 assigned barratry claimants and adding a Designation of Responsible Third Parties (Billy Shepherd, Scott Walker, Steve Seymour, Kirk Ladner). Addressed to the Honorable Judge of said Court. | PLEAD-1 | N/A | Phase 1 | 2018-11-06_OA_Kassab-2nd-Amended-Answer-CC_FILED.pdf | Plaintiffs take nothing; Kassab recovers on counterclaims and against third-party defendants including actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other just relief | 11/6/2018 2:08 PM Chris Daniel - District Clerk Harris County Envelope No. 28831260 By: ARIONNE MCNEAL Filed: 11/6/2018 2:08 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIrAL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LANCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S SECOND AMENDED ANSWER, AFFIRMATIVE DEFENSES AND COUNtTERCLAIM, AND DESIGNATION OF RESPONSIBLE THIRD PARTIES TO THE HONORABLE JUDGE OF SAID COURT: s COMES NOW, Defendants, Lance Christopher Kgassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm and files this theBir Second Amended Answer, Affirmative Defenses, and Counterclaim, and Designation of Ryesponsible Third Parties, and would respectfully show the Court as follows; a RULfE 47 STATEMENT The Kassab Defendants, in teheir capacity as Counter-Plaintiffs, seek monetary relief of more than $1,000,000.00. f y PARTIES Plaintiff, Michael A. Pohl is an individual lawyer residing in Colorado. Plaintiff, Laawl Offices of Michael A. Pohl is a law firm set up for the practice of law in various states of ithe union, including Texas. Defendant, Scott Favre is a nonresident individual residing in Mississippi. Defendant, Scott M. Favre, PA, LLC is a nonresident limited liability company located in Mississippi. Defendant, Precision Marketing Group, LLC is a nonresident limited liability company located in Mississippi. Defendant, F. Douglas Montague III is a nonresident individual residing in Mississippi. Defendant, Montague, Pittman & Varnado, PA is a nonresident professional association located in Mississippi. Defendant, Tina Nicholson is an individual residing in Texas. k Defendant, Baker Nicholson, LLP, d/b/a Baker Nicholson Law Firm ils a limited liability partnership located in Texas. c Defendant, Counter-Plaintiff, Lance Christopher Kassab is an sindividual residing in Texas. Defendant, Counter-Plaintiff, Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm is a professional corporation… |
| 8 | 2018-10-24 | OA | Kassab | 1st Amended Answer with Counterclaims | Kassab's First Amended Answer, Affirmative Defenses, and Counterclaim for Civil Barratry, filed October 24, 2018 simultaneously with TCPA Motion to Dismiss | Filed October 24, 2018 simultaneously with the TCPA Motion to Dismiss. This amends Kassab's original answer (Filing #2) by adding res judicata as a 17th affirmative defense. Maintains general denial, 17 affirmative defenses, specific denials regarding conditions precedent, and counterclaims for civil barratry on behalf of 150 assigned claimants. | PLEAD-1, CC-1 | N/A | Phase 1 | 2018-10-24_OA_Kassab-1st-Amended-Answer-CC_FILED.pdf | Plaintiffs take nothing on their claims; Kassab recovers on counterclaims including actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other just relief | 10/24/2018 2:33 PM Chris Daniel - District Clerk Harris County Envelope No. 28526297 By: ARIONNE MCNEAL Filed: 10/24/2018 2:33 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIrAL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LANCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S FIRST AMENDED ANSWER, AFFIRMATIVE DEFENSES AND COUNtTERCLAIM TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendants, Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm and files this their First Armended Answer, Affirmative Defenses, and Counterclaim, and would respectfully show the Court as follows; RULE 47 SiT l ATEMENT The Kassab Defendants, in their caMpacity as Counter-Plaintiffs, seek monetary relief of more than $1,000,000.00. o PARTIES Plaintiff, Michael A. PoOhl is an individual lawyer residing in Colorado. Plaintiff, Law Offipces of Michael A. Pohl is a law firm set up for the practice of law in various states of the union, including Texas. Defendant, iScott Favre is a nonresident individual residing in Mississippi. Defenodant, Scott M. Favre, PA, LLC is a nonresident limited liability company located in Mississippi. Defendant, Precision Marketing Group, LLC is a nonresident limited liability company located in Mississippi. Defendant, F. Douglas Montague III is a nonresident individual residing in Mississippi. Defendant, Montague, Pittman & Varnado, PA is a nonresident professional association located in Mississippi. Defendant, Tina Nicholson is an individual residing in Texas. Defendant, Baker Nicholson, LLP, d/b/a Baker Nicholson Law Firm is a klimited liability partnership located in Texas. l Defendant, Counter-Plaintiff, Lance Christopher Kassab is an indicvidual residing in Texas. Defendant, Counter-Plaintiff, Lance Christopher Kassab, P.C.s d/b/a The Kassab Law Firm is a professional corporation located in Texas. JURISDICTION AND VENUE This matter is within the jurisdictional limitsu of t… |
| 4 | 2018-10-15 | OA | Montague | Montague’s answer subject to special appearance | Defendants F. Douglas Montague III and Montague Pittman & Varnado, P.A.'s Original Answer Subject to Their Special Appearance, including general denial, 12 affirmative defenses, and request for disclosure | Montague Defendants' initial responsive pleading filed October 15, 2018, subject to their previously filed Special Appearance challenging personal jurisdiction. This answer preserves their jurisdictional objection while also responding to the merits of Pohl's Original Petition. | PLEAD-1 | N/A | Phase 1 | 2018-10-15_OA_Montague-Answer-Subject-to-Appearance_FILED.pdf | Grant of special appearance dismissing Montague Defendants for lack of personal jurisdiction; alternatively, denial of all relief against Montague Defendants with a take-nothing judgment; costs of court; and all other relief to which they may be justly entitled | 10/15/2018 10:49 AM Chris Daniel - District Clerk Harris County Envelope No. 28273574 By: ARIONNE MCNEAL Filed: 10/15/2018 10:49 AM NO. 2018-58419 MICHAEL POHL, ET AL § IN THE DISTRICT COURT OF Plaintiffs, § v. § § HARRIS COUNTY, TEXAS LANCE KASSAB, ET AL § r § C l Defendants. § 189TH JUDICIAL DISTRICT DEFENDANTS F. DOUGLAS MONTAGUE IItI AND MONTAGUE PITTMAN & VARNADO, P.A.’S ORDIGiINAL ANSWER SUBJECT TO THEIR SPECIAL APPEARANCE Subject to the their previously filed Special Appearance, Defendants F. Douglas Montague III and Montague Pittman & Varnado, P.AB. (“Defendants”) file this Original Answer to Plaintiff’s Original Petition and respectfully show the following: aI. GENERAL DENIAL 1.1. Pursuant to Rule 92, Defendants denies the material allegations made in the Plaintiffs’ Original Petition and aniy petition that may be filed hereinafter by way of amendment or supplement, and demand strict proof thereof by a preponderance of the evidence at trial. o II. AFFIRMATIVE AND ADDITIONAL DEFENSES Defendancts further assert the following additional and affirmative defenses in the alternative subject to their special appearance: 2.1. In the alternative, Plaintiffs’ claims are barred by a lack of standing. Specifically, Plaintiff did not have an attorney-client relationship with the Defendants nor were these Defendants a party or an attorney for a party to the underlying Pohl litigation with Favre and Precision. Therefore, these Defendants owe no duty to Plaintiffs. Moreover, the referral of cases to specialists are the type of professional services that routinely and commonly fall within the services that an attorney would provide and that the Defendants do provide, which would thereby provide immunity to these Defendants from liability. Consequently, there is no basis to assert a claim of liability whether by way of conversion, theft of trade secrets, conspiracky or otherwise against attorneys who are simply discharging traditional legal tasks. l 2.2. In the alternative, Plaintiffs’ claims for conspiracy and reclat… |
| 2 | 2018-10-08 | OA | Kassab | Kassab’s initial answer with counterclaims | Kassab Defendants' Original Answer, Affirmative Defenses, and Counterclaim for Civil Barratry, including general denial, 16 affirmative defenses, specific denials, and counterclaims based on assigned barratry claims | Kassab's initial responsive pleading to Pohl's Original Petition, filed October 8, 2018, approximately six weeks after suit was commenced. Includes both defensive pleading (general denial, 16 affirmative defenses, specific denials) and offensive counterclaims for civil barratry based on assigned claims from Pohl's former clients. | PLEAD-1, CC-1 | N/A | Phase 1 | 2018-10-08_OA_Kassab-Answer-and-CC_FILED.pdf | That Plaintiffs recover nothing on their claims; actual and consequential damages on counterclaims; statutory damages; pre- and post-judgment interest; attorneys' fees and costs; and all other relief to which Defendants/Counter-Plaintiffs may be justly entitled | 10/8/2018 1:34 PM Chris Daniel - District Clerk Harris County Envelope No. 28104847 By: Brianna Denmon Filed: 10/8/2018 1:34 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIrAL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LANCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIM t TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendants, Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm and files this their Origirnal Answer, Affirmative Defenses, and Counterclaim, and would respectfully show the Court as follows; RULE 47 SiT l ATEMENT The Kassab Defendants, in their caMpacity as Counter-Plaintiffs, seek monetary relief of more than $1,000,000.00. o PARTIES Plaintiff, Michael A. PoOhl is an individual lawyer residing in Colorado. Plaintiff, Law Offipces of Michael A. Pohl is a law firm set up for the practice of law in various states of the union, including Texas. Defendant, iScott Favre is a nonresident individual residing in Mississippi. Defenodant, Scott M. Favre, PA, LLC is a nonresident limited liability company located in Mississippi. Defendant, Precision Marketing Group, LLC is a nonresident limited liability company located in Mississippi. Defendant, F. Douglas Montague III is a nonresident individual residing in Mississippi. Defendant, Montague, Pittman & Varnado, PA is a nonresident professional association located in Mississippi. Defendant, Tina Nicholson is an individual residing in Texas. Defendant, Baker Nicholson, LLP, d/b/a Baker Nicholson Law Firm is a klimited liability partnership located in Texas. l Defendant, Counter-Plaintiff, Lance Christopher Kassab is an indicvidual residing in Texas. Defendant, Counter-Plaintiff, Lance Christopher Kassab, P.C.s d/b/a The Kassab Law Firm is a professional corporation located in Texas. JURISDICTION AND VENUE This matter is within the jurisdictional limitsu of this Court and Plaint… |
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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
);