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2 rows where doc_type = "RPL" 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 |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 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… |
| 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
);