Court Filings
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2 rows where doc_type = "OBJ" and party = "Pohl" 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 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 47 | 2022-11-30 | OBJ | Pohl | Objection to Kassab supp. RTP | Pohl's Objection to Kassab's Supplemental Motion to Designate Responsible Third Parties | Filed November 30, 2022 in response to Kassab's Supplemental RTP Motion filed November 15, 2022. Judge Dollinger denied Kassab's original RTP Motion on October 31, 2022 (finding Pohl's objection was 'well taken') and gave Kassab 14 days to replead. Kassab filed 15 days later (one day late). Pohl argues the supplemental motion contains no new factual allegations. Pohl does not object to designation of Favre and Precision as RTPs. | RTP-1 | N/A | Phase 3 | 2022-11-30_OBJ_Pohl-Objection-to-Kassab-Supp-RTP_FILED.pdf | Deny Kassab's Supplemental RTP Motion without leave for Kassab to attempt to replead, as Kassab failed to plead sufficient facts after already being granted leave to replead | 11/30/2022 4:26 PM Marilyn Burgess - District Clerk Harris County Envelope No. 70583280 By: Ashley Lopez Filed: 11/30/2022 4:26 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. § 189TH JUDrICIAL DISTRICT POHL’S OBJECTION TO KASSAB’S SUPPLEMENTAL MOTION TO DESIGNATE RESPONSIBLE THIRD PARTsIES Plaintiffs Michael Pohl and Law Office of Michael A. Pohl PLLC (collectively “Pohl”) file this Objection to Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm’s Supplemental Motion to Designate Responsible Third Parties1 (the “Supplemental RTP Motion”) and would showa the Court as follows: Kassab’s Supplemental RTP Motion does not address the failings of the original RTP Motion. The Court denied Kassab’se first RTP Motion2 because Kassab failed to plead sufficient facts showing that the alleged resfponsible third parties were responsible for the harms underlying Pohl’s claims. Kassab was ygiven a chance to replead with sufficient new facts to demonstrate liability. However, thCe Supplemental RTP Motion contains the same factual allegations copied and pasted from the briefing before the Court when it denied the RTP Motion. Kassab tried to disguise this bfyf reordering and lightly paraphrasing or modifying the allegations. But Kassab 1 This Objection is primarily directed at Kassab’s Supplemental RTP Motion, filed Nov. 15, 2022. Kassab also filed a Second Supplemental Motion to Designate Responsible Third Parties, filed Nov. 22, 2022 (“Second Supplemental RTP Motion”). Pohl does not object to the designation of Scott Favre and Precision Marketing Group, LLC as responsible third parties. However, Pohl objects to the Second Supplemental RTP Motion, on the same grounds as set forth in this briefing, to the extent that it seeks the same relief sought in the Supplemental RTP Motion or seeks to designate anyone as a responsible third party other than Scott Fav… |
| 28 | 2022-05-31 | OBJ | Pohl | Pohl’s objection to RTP designation | Pohl's Objection to Kassab's Motion to Designate Responsible Third Parties, arguing the designated persons did not cause or contribute to the harms underlying Pohl's tort claims and that Kassab failed to satisfy pleading requirements | Phase 3 response to Kassab's RTP motion. Pohl objects on grounds that the designated persons are not responsible for the specific harms underlying Pohl's conversion and TUTSA claims, distinguishing between harm to Pohl and general connection to events. Also argues Kassab failed to timely disclose RTP identities in discovery. Filed by Reynolds Frizzell LLP. | RTP-1 | N/A | Phase 3 | 2022-05-31_OBJ_Pohl-Objection-to-Kassab-RTP-Designation_FILED.pdf | Deny Kassab's Motion to Designate Responsible Third Parties with leave for Kassab to attempt to replead | 5/31/2022 5:00 PM Marilyn Burgess - District Clerk Harris County Envelope No. 64998436 By: cassie combs Filed: 5/31/2022 5:00 PM CAUSE NO. 2018-58419 MICHAEL A. POHL AND LAW OFFICE OF § IN THE DISTRICT COURT OF MICHAEL A. POHL, PLLC, § Plaintiffs, § V. § k § r SCOTT FAVRE and SCOTT M. FAVRE PA, § l LLC; PRECISION MARKETING GROUP, § HARRIS COUNTY, TEXAS LLC; LANCE CHRISTOPHER KASSAB and § c LANCE CHRISTOPHER KASSAB, P.C. d/b/a § r THE KASSAB LAW FIRM; TINA § s NICHOLSON and BAKER NICHOLSON, § D LLP d/b/a BAKER NICHOLSON LAW § FIRM; and DOUGLAS MONTAGUE III and § s MONTAGUE PITTMAN & VARNADO, P.A., § Defendants. § r189TH JUDICIAL DISTRICT POHL’S OBJECTION TO KASSAB’S MOTION TO DESIGNATE RESPONSIBLE THIRD PARTIES Plaintiffs Michael Pohl and Law Officae of Michael A. Pohl (collectively “Pohl”) file this Objection to Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm’s Motion to Desiegnate Responsible Third Parties (the “Motion”) and would show the Court as follows: f y I. INTRODUCTION The Court shouCld deny Kassab’s Motion because he fails to allege facts showing how the alleged responsiblea third parties are responsible for the harms underlying Pohl’s tort claims. Kassab seeks tfo designate eight different allegedly responsible third parties—Billy Shepherd (“ShepheUrd”), Scott Walker (“Walker”), Steve Seymour (“Seymour”) Kirk Ladner (“Ladner”), Dona Pohl (“Dona”), Edgar Jaimes (“Jaimes”), Ken Talley (“Talley”), and Magdalena Santana (“Santana”) (collectively, the “Alleged RTPs”). None of the Alleged RTPs “caused or contributed to causing” the harms underlying Pohl’s claims. TEX. CIV. PRAC. & REM. CODE § 33.011(6). Reading Kassab’s Motion, one might be forgiven for thinking that a responsible third party is any person who bears some (or any) connection with events related to a lawsuit and whose actions could allegedly have impacted the amount of damages suffered by a claimant. See generally Motion. But Texas has not adopted a “butterfly effect” theory okf proportionate… |
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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
);