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| filing_id | date ▲ | doc_type | party | description | doc_type_detail | procedural_posture | chain | outcome | phase | filename | relief_requested | full_text |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 60 | 2023-09-18 | RPL | Pohl | Reply ISO Mtn for Final Judgment | Pohl's Reply in Support of Motion for Entry of Final Judgment, responding to Kassab's five objections to the proposed judgment regarding exemplary damages unanimity, attorneys' fees recoverability, overlapping damages, conspiracy preemption, and Precision's exoneration | Reply brief filed September 18, 2023 in the 281st Judicial District Court, Harris County, Cause No. 2018-58419. Filed three days after Kassab's September 15, 2023 objections to Pohl's September 5, 2023 Motion for Entry of Final Judgment. Addresses each of Kassab's five objections and argues the court must enter judgment consistent with the jury verdict. | JDGMT-1 | N/A | Phase 5 | 2023-09-18_RPL_Pohl-Reply-ISO-Mtn-for-Final-Judgment_FILED.pdf | That the Court overrule Kassab's objections and enter the Final Judgment in the form attached to the Motion as Exhibit B | 9/18/2023 8:21 PM Marilyn Burgess - District Clerk Harris County Envelope No. 79681130 By: Bonnie Lugo Filed: 9/18/2023 8:21 PM CAUSE NO. 2018-58419 MICHAEL A. POHL AND LAW OFFICE OF § IN THE DISTRICT COURT OF MICHAEL A. POHL, PLLC, § Plaintiffs, § V. § k § e SCOTT FAVRE and SCOTT M. FAVRE PA, § C 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, § LLP d/b/a BAKER NICHOLSON LAW § s FIRM; and DOUGLAS MONTAGUE III and § s MONTAGUE PITTMAN & VARNADO, P.A., § Defendants. § r281ST JUDICIAL DISTRICT POHL’S REPLY IN SUPPORT OF HIS MOTION FOR ENTRY OF FINAL JUDGMENT On September 5, 2023, Plaintiffs Michaell Pohl and Law Offices of Michael A. Pohl PLLC (collectively, “Pohl”) filed their motion foMr entry of a Final Judgment and to adjudge costs (the “Motion”). On September 15, 2023, Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm’s (collectively, “Kassab”) filed Objections to Pohl’s Proposed Final Judgment (the “Response”). Kassab fails to demonstrate in the Response that the Court would commit error in any way by entering final judgment in the form requested by Pohl. OVERVIEW Kassab liscts five general objections to entry of judgment. None of the objections withstand scrutiny. • Kassab objects to the inclusion of exemplary damages in the judgment because he contends the Jury’s answer of “Yes” to Question 17 was not unanimous. But Kassab is factually incorrect because, on its face, the Jury Verdict shows that the Jury unanimously answered “Yes” to Question 17. The Court instructed the Jury to only answer “Yes,” in response to Question 17 if it was unanimous, and the Jury is presumed to have followed those instructions. Moreover, the Court instructed the Jury to answer Question 19 “only if you unanimously answered “Yes” to Question no. 17,” and the Jury answered Question 19. k • Kassab objects to the inclusion of attorneys’ fees from a p… |
| 54 | 2023-03-15 | RPL | Kassab | Reply ISO Mtn to Rule | Kassab Defendants' Reply in Support of Their Motion to Rule on Plaintiffs' Objections to Kassab's Deposition on Written Questions of Scott Favre | Filed March 15, 2023 in the 281st Judicial District Court before Judge Christine Weems. Kassab replies to Pohl's response (filing #53) opposing Kassab's motion to rule on objections to his DWQ of Scott Favre, arguing his questions are not leading, Pohl's own questions are leading, and Pohl's boilerplate objections are waived. | MSJ-2R | N/A | Phase 4 | 2023-03-15_RPL_Kassab-Reply-ISO-Mtn-to-Rule_FILED.pdf | Overrule Pohl's objections to Kassab's deposition on written questions of Scott Favre | 3/15/2023 5:09 PM Marilyn Burgess - District Clerk Harris County Envelope No. 73705718 By: Bonnie Lugo Filed: 3/15/2023 5:09 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS § k § e SCOTT FAVRE, et al § 281st JUDICCIAL DISTRICT KASSAB DEFENDANTS’ REPLYIN SUPPORT OF THIER MOTION TO RULE ON PLAINTIFFS’ OBJEtCTIONS TO THE KASSAB DEFENDANTS’ NOTICEi TO TAKE DEPOSITION ON WRITTEN QUESTIONS OF SCOTT FAVRE TO THE HONORABLE JUDGE CHRISTINE WEEMeS: Defendants, Lance Christopher Kassab aund Lance Christopher Kassab, P.C. D/B/A The Kassab Law Firm (collectively “Knassab”) file this, their Reply In Support of Their Rule on Plaintiffs’ Objectionsa to the Kassab Defendants Notice to Take Deposition on Written Questions of Scott Favre and would respectfully show the following. e KASSAB DOES N OOT f AGREE THAT HIS QUESTIONS ARE LEADING, BUT POHL’S QUESTIONS TO FAVRE WERE Plaintiffs claimo “[t]here is no dispute that Kassab asked leading questions, nor does Kassab clontend that any of Pohl’s “leading” objections were directed at non-leading quiestions.”1 Pohl’s claim is false as none of the questions propounded by Kassab are leading in the first place and Kassab made that abundantly clear to Pohl’s counsel in an email, stating “[t]he objections are all meritless.”2 After stating that all the objections were meritless, Kassab stated “[a]dditionally, your clients’ 1 Exhibit F, p. 3 2 Exhibit A. leading objections are improper” for two other reasons: leading questions are permitted on cross examination and for hostile witnesses.3 Kassab’s motion to rule simply focused on Plaintiffs’ absurd argument—meaning even if Kassab’s questions were leading, which they are not, Favre should be treated as a hostile wkitness. One need only look to the questions Pohl served Favre to Csee that Pohl has persuaded Favre to contradict his prior testimony to help Pohl with his frivolous retaliatory lawsuit against Kassab. i For instance, Favre has already testified in an affidavit and in Federal Cour… |
| 24 | 2022-02-04 | RPL | Pohl | Pohl’s reply ISO MSJ on counterclaims | Plaintiffs' Reply in Support of Their Motion for Summary Judgment on Defendants' Counterclaims for Civil Barratry | Pohl's reply brief supporting his MSJ on Kassab's barratry counterclaims, filed February 4, 2022. This is the final brief in the CC-1 motion chain before the court's ruling (which ultimately granted Pohl's motion). Attorney: Jean C. Frizzell of Reynolds Frizzell LLP. | CC-1 | N/A | Phase 2 | 2022-02-04_RPL_Pohl-Reply-ISO-MSJ-on-CC_FILED.pdf | Grant summary judgment dismissing Kassab's counterclaims for civil barratry | 2/4/2022 3:45 PM Marilyn Burgess - District Clerk Harris County Envelope No. 61466983 By: Deandra Mosley Filed: 2/4/2022 3:45 PM CAUSE NO. 2018-58419 MICHAEL A. POHL AND LAW OFFICE OF § IN THE DISTRICT COURT OF MICHAEL A. POHL, PLLC, § Plaintiffs, § V. § k § e SCOTT FAVRE and SCOTT M. FAVRE PA, § C 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, § LLP d/b/a BAKER NICHOLSON LAW § s FIRM; and DOUGLAS MONTAGUE III and § s MONTAGUE PITTMAN & VARNADO, P.A., § Defendants. § r189TH JUDICIAL DISTRICT PLAINTIFFS’ REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS’ COUNTERCLAIMS Plaintiffs Michael Pohl and Law Officae of Michael A. Pohl (collectively “Pohl”) file this Reply in Support of Their Motion for Summary Judgment on Defendants’ Counterclaims for Civil Barratry. e In his Response to Plfaintiffs’ Motion (the “Response”) Kassab admits that the Assignments1 underlying hisy counterclaims were shams that altered nothing about the ownership of the claims and wereC made explicitly for the purpose of circumventing the statute of limitations and fomenting otherwise barred litigation. See Response, at 6 (“Seeing Pohl’s retaliatory suit as a means to potenftfially revive the barratry claims dismissed on limitations in Brumfield and Gandy, Kassab aUnd his clients executed 242 Limited Assignments.”); see also Declaration of Lance Kassab ¶ 12, Ex. 5 to the Response (after purported “assignment,” clients retained 60% interest in claims and Kassab retained 40% contingent fee interest). These admissions demonstrate the 1 Terms defined in Plaintiffs’ Motion carry the same meaning in this Reply. invalidity of the Assignments and therefore the Counterclaims. In addition to effectively admitting that the Assignments are shams, Kassab’s Response fails to rebut any of the other bases on which Pohl moved for summary judgment. The Court can resolve Pohl’s Motion based on a s… |
| 18 | 2021-08-02 | RPL | Kassab | Kassab’s reply ISO Traditional MSJ | Kassab's Objections to Pohl's Response and Reply in Support of Traditional Motion for Summary Judgment, with extensive evidentiary objections and rebuttal arguments on all three grounds | Reply brief filed one week after Pohl's response (July 26, 2021) to Kassab's Traditional MSJ. Filed August 1-2, 2021. Contains two major sections: (1) detailed paragraph-by-paragraph evidentiary objections to Pohl's Declaration (Exhibit A) seeking to strike key paragraphs and exhibits as conclusory, hearsay, or lacking foundation; (2) substantive reply arguments on limitations, res judicata, and attorney immunity. Kassab represents himself pro se with David Eric Kassab. | MSJ-1 | N/A | Phase 2 | 2021-08-02_RPL_Kassab-Reply-ISO-Traditional-MSJ_FILED.pdf | Sustain all evidentiary objections; strike Paragraphs 5, 6, 7, 8, 9, and 10 of Pohl's Declaration and Exhibits 1-2; grant Traditional Motion for Summary Judgment ordering that Plaintiffs take nothing | 8/1/2021 7:39 PM Marilyn Burgess - District Clerk Harris County Envelope No. 55892722 By: Deandra Mosley Filed: 8/2/2021 12:00 AM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIALk DISTRICT THE KASSAB DEFENDANTS’ OBJECTIONS TO PLAINTIFCFS’ RESPONSE AND REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT TO THE HONORABLE JUDGE SCOT “DOLLI” DOLLINGEtR: Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a/ The Kassab Law Firm file this, their Objections to Plaeintiffs’ Response and Reply in Support of Motion for Summary Judgment uand would respectfully show the following. BJECTIONS Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a/ The Kassab Law Firm i(collectively, “Kassab”) object to Plaintiffs’ Exhibit A, the sworn declaration of Michael A. Pohl, because statements contained in this declaration are concluosory, contain hearsay and contain no foundation or predicate to support personall knowledge, and thus, constitute no evidence at all. Conclusiory affidavits do not raise fact issues and are incompetent evidence as a matter of law. Ryland Group, Inc. v. Hood, 924 S.W.2d 120, 122 (Tex. 1996); Stephens v. Precision Drilling Oilfield Servs. Corp., No. 01-11-00326-CV, 2013 Tex. App. LEXIS 5700, at *19 (Tex. App.—Houston [1st Dist.] May 9, 2013, no pet.) (mem. op.). “A conclusory statement is one that does not provide the underlying facts to support the conclusion.” Dolcefino v. Randolph, 19 S.W.3d 906, 930 (Tex. App. – Houston [14th Dist.] 2000, pet. denied). Moreover, an affidavit is conclusory when it expresses “a factual inference without stating the underlying facts on which the inference is based.” E.I. du Pont de Nemours & Co. v. Shell Oil Cok., 259 S.W.3d 800, 809 (Tex. App.—Houston [1st Dist.] 2007, pet. denied). ThusC, bare conclusions are not evidence and are not probative of any facts. See Bavishi v. Sterling Air Conditioning, Inc., No. 01-10-00610-CV, 2011 Tex. App.i LEXIS 6271, at *24-… |
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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
);