Court Filings
Data license: Public court records
8 rows where outcome = "N/A", party = "Pohl" and phase = "Phase 3" sorted by date descending
This data as json, CSV (advanced)
Suggested facets: date, chain, date (date)
| filing_id | date ▲ | doc_type | party | description | doc_type_detail | procedural_posture | chain | outcome | phase | filename | relief_requested | full_text |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 46 | 2022-11-30 | MSJ | Pohl | Partial MSJ on Barratry Liability | Plaintiffs' Rule 166(g) Motion on Barratry Liability and Specific Affirmative Defenses Asserted by the Kassab Defendants | Pre-trial motion filed November 30, 2022 by Pohl, five days before the December 5, 2022 trial setting. Seeks legal rulings under Tex. R. Civ. P. 166a(g) to narrow trial issues by: (1) finding barratry is not legally relevant to this lawsuit, and (2) striking 10+ of Kassab's affirmative defenses as barred as a matter of law. | MSJ-3 | N/A | Phase 3 | 2022-11-30_MSJ_Pohl-Partial-MSJ-Barratry-Liability_FILED.pdf | Find that: (1) establishing whether barratry occurred is not legally relevant to this lawsuit; (2) Kassab's affirmative defenses of unlawful acts, illegality, criminal acts, in pari delicto, justification, immunity under Rule 17.09, unclean hands, release, accord and satisfaction, estoppel, subject to a valid contract, assumption of the risk, and contribution are barred as a matter of law | 11/30/2022 8:20 PM Marilyn Burgess - District Clerk Harris County Envelope No. 70589892 By: Deandra Mosley Filed: 11/30/2022 8:20 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et. al § IN THE DISTRICT COURT OF Plaintiffs, § V. § HARRIS COUNTY,k TEXAS § r LANCE CHRISTOPHER § l KASSAB, et. al § § c Defendants. § 189TH JUDrICIAL DISTRICT PLAINTIFFS’ RULE 166(g) MOTION ON BARRATRY LIDABILITY AND SPECIFIC AFFIRMATIVE DEFENSES ASSERTED BY THE KASSAB DEFENDANTS Under Texas Rule of Civil Procedure 166(g), Plaintiffs Michael Pohl and Law Office of Michael A. Pohl PLLC (collectively “Pohl”) file this Motion on the issues of the relevance of barratry liability and the legal viability of specific affirmative defenses asserted by the Kassab defendants (the “Motion”). Pohl requests tahat the Court find Defendants Lance Christopher Kassab and Lance Christopher Kassab P.C.’s (collectively, “Kassab”) theories regarding establishing barratry and certain otheer legal defenses fail as a matter of law. f I. STANDARD Under Texas Rule ofy Civil Procedure 166(g), this Court can decide legal issues at pretrial “to assist in the disposition of the case without undue expense or burden to the parties . . . .” See Tex. R. Civ. P. 166a(g). Allowing this trial to subsume the question of whether Pohl committed barratry, in connfection with clients whose information Kassab later misappropriated, would greatly extend the length of trial, and it would needlessly complicate the issues presented to the jury. A legal determination by this Court that whether barratry did in fact occur is immaterial to Pohl’s claims—whether as a matter of denial or as a defense—would assist in disposing of this case with less undue burden and expense. Furthermore, determining whether certain defenses fail as a matter of law is a set of legal questions the Court can decide to appropriately focus the trial in this case. II. DISCUSSION To prevent “undue expense” and additional “burden to the parties,” and to ensure that trial does not proceed for longer than is necessary, th… |
| 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… |
| 41 | 2022-09-21 | NTC | Pohl | Filing evidence and request for leave | Pohl Plaintiffs' Notice of Filing of Evidence in Support of Claims of Privilege and Request for Leave | Notice filed September 21, 2022 pursuant to Tex. R. Civ. P. 193.4, filing Pohl's declaration to support privilege claims in response to Kassab Defendants' Fifth Set of Written Discovery Requests and their related Motion to Compel. Filed before Judge Scot Dollinger, 189th Judicial District, Harris County, Texas. | MSJ-3 | N/A | Phase 3 | 2022-09-21_NTC_Pohl-Filing-Evidence-and-Request-for-Leave_FILED.pdf | Leave to file the declaration of Michael A. Pohl in support of privilege claims less than seven days in advance of the September 23, 2022 hearing on Kassab's Motion to Compel | 9/21/2022 9:03 PM Marilyn Burgess - District Clerk Harris County Envelope No. 68499533 By: Ashley Lopez Filed: 9/21/2022 9:03 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 THE POHL PLAINTIFFS’ NOTICE OF FILING OF EVIDENCE IN SUPPORT OF CLAIMS OF PRIVILEGE AND REQUEST FOR LEAVE TO THE HONORABLE JUDGE SCOT “DOaLLI” DOLLINGER: Pursuant to Texas Rule of Civil Procedure 193.4, Plaintiffs Michael A. Pohl and Law Office of Michael A. Pohl, PLLC fieles and serves the attached declaration of Michael A. Pohl which will be used to support thfe claims of privilege made by Pohl in response to the Kassab Defendants’ Fifth Set of Wriytten Discovery Requests. This declaratioCn is being filed as a result of the Kassab Defendants’ Motion to Compel Removal of Pohl’sa Objections and Properly Respond to Discovery, filed Sept. 19, 2022 (the “Motion”)—whfich was set for hearing on Sept. 23, 2022. Given that the Motion was both filed and set for hearing less than seven days in advance of the hearing date, Pohl requests leave for the filing of this declaration less than seven days in advance of the hearing under Texas Rule of Civil Procedure 193.4(a). The Kassab Defendants and the Montague Defendants do not oppose this request for leave. Dated: September 21, 2022 Respectfully submitted, REYNOLDS FRIZZELL LLP By: /s/ Jean C. Frizzell Jean C. Frizzell State Bar No. 07484650 k 1100 Louisiana St., Suite 3500 e Houston, Texas 77002 C l Tel. 713.485.7200 Fax 713.485.7250 c jfrizzell@reynoldsfrizzell.rcom Attorney for PlaintifDfs Michael Pohl and Law Office ofs Michael A. … |
| 39 | 2022-09-18 | NTC | Pohl | Withdrawal of partial MSJ on aff. def. | Pohl Plaintiffs' Notice of Drawing Down from Hearing Plaintiffs' Motion for Partial Summary Judgment on Defendants' Affirmative Defenses that Seek to Relitigate Failed Barratry Claims and No-Evidence Motion on the Remaining Affirmative Defenses | Notice submitted September 18, 2022 (filed by clerk September 19, 2022) withdrawing Pohl's own motion for partial summary judgment on affirmative defenses from the September 19, 2022 hearing before Judge Scot 'Dolli' Dollinger, while defendants' MSJs remained pending for the same hearing date. Filed by Jean C. Frizzell of Reynolds Frizzell LLP. | MSJ-3 | N/A | Phase 3 | 2022-09-18_NTC_Pohl-Withdrawal-of-Partial-MSJ-on-Aff-Def_FILED.pdf | Request that Plaintiffs' Motion for Partial Summary Judgment on Defendants' Affirmative Defenses be drawn down from the September 19, 2022 hearing | 9/18/2022 5:42 PM Marilyn Burgess - District Clerk Harris County Envelope No. 68364897 By: Deandra Mosley Filed: 9/19/2022 12:00 AM 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 THE POHL PLAINTIFFS’ NOTICE OF DRAWING DOWN FROM HEARING PLAINTIFFS’ MOTION FOR PARTIAL SUMMARY JUDGMENT ON DEFENDANTS’ AFFIRMATIVE DEFElNSES THAT SEEK TO RELITIGATE FAILED BARRATRY CLAIMS AGaAINST PLAINTIFFS AND NO-EVIDENCE MOTION ON THE REMAMINING AFFIRMATIVE DEFENSES TO THE HONORABLE JUDGE SCOT “DOLLI” DOLLINGER: Plaintiffs Michael A. Pohl and Law Office of Michael A. Pohl, PLLC file this notice to draw down Plaintiffs’ Motion for Partial Summary Judgment on Defendants’ Affirmative Defenses that Seek to Relitigate Failed Barratry Claims Against Plaintiffs and No-Evidence Motion on the Remaining Affirmative Defenses, filed on August 29, 2022. This motion is currently set for hcearing on September 19, 2022, and Plaintiffs request that it be drawn down from that hearing so that the motion is not heard at that time. Dated: September 18, 2022 Respectfully submitted, REYNOLDS FRIZZELL LLP By: /s/ Jean C. Frizzell Jean C. Frizzell State Bar No. 07484650 k 1100 Louisiana St., Suite 3500 e Houston, Texas 77002 C l Tel. 713.485.7200 Fax 713.485.7250 c jfrizzell@reynoldsfrizzell.rcom Attorney for PlaintifDfs Michael Pohl and Law Office ofs Michael A. Pohl, PLLC CERTIFICATE OF SERVICE I hereby certify that a true and correct coply of this document was served on all counsel of record pursuant to the Texas Rules of Civil Praocedure on this 18th day of September, 2022. o /s/ Jean C… |
| 38 | 2022-09-15 | RSP | Pohl | Pohl’s response to MTA | Plaintiffs' Response to the Kassab Defendants' Motion to Abate Trial Setting — opposes abatement of four-year-old case on eve of preferential trial setting, arguing future damages do not justify abatement and unlawful acts defense has been preempted | Response filed September 15, 2022 by Jean C. Frizzell of Reynolds Frizzell LLP opposing Kassab's motion to abate the trial setting in a four-year-old case with a preferential trial setting. Incorporates by reference Pohl's September 12, 2022 responses to defendants' summary judgment motions. | MTA-1 | N/A | Phase 3 | 2022-09-15_RSP_Pohl-Response-to-Kassab-MTA-Trial_FILED.pdf | Deny Kassab's Motion to Abate Trial Setting and allow the case to proceed to trial during its current preferential trial setting | 9/15/2022 5:08 PM Marilyn Burgess - District Clerk Harris County Envelope No. 68313271 By: Deandra Mosley Filed: 9/15/2022 5:08 PM CAUSE NO. 2018-58419 MICHAEL A. POHL AND LAW OFFICE § IN THE DISTRICT COURT OF OF MICHAEL A. POHL, PLLC, § Plaintiffs, § v. § k § e SCOTT FAVRE and SCOTT M. FAVRE PA, § C l LLC; PRECISION MARKETING GROUP, § 189TH JUDICIAL DISTRICT LLC; LANCE CHRISTOPHER KASSAB and § c LANCE CHRISTOPHER KASSAB, § r P.C. d/b/a THE KASSAB LAW FIRM; TINA § NICHOLSON and BAKER NICHOLSON, LLP § d/b/a BAKER NICHOLSON LAW FIRM; and § s DOUGLAS MONTAGUE III and MONTAGUE § PITTMAN & VARNADO, P.A., § g Defendants. § r HARRIS COUNTY, TEXAS PLAINTIFFS’ RESPONSE TO THE KASSAB DEFENDANTS’ MOTION TO ABATEy TRIAL SETTING Plaintiffs Michael Pohl and Law Officaes of Michael A. Pohl (collectively, “Pohl”) file this this response to Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C.’s (collectively, “Kassab”) Motion to Abeate Trial Setting (the “Motion to Abate”). Pohl requests that the Court deny Kassab’s Motion fto Abate and allow this four-year-old case to be tried during its current preferential trial settiyng—a trial setting that Kassab appears to be trying to avoid. Kassab argues Cthat this case should be abated for two reasons: (1) Pohl is still incurring damages; and (2) the outcome of a separate lawsuit—the Cheatham case—will impact Kassab’s illegality (unlafwfful acts doctrine) defense. Neither argument has merit. First, the existence of future daUmages does not justify abatement. For Pohl to recover future damages, he must satisfy the ordinary standard of showing to the jury that he will sustain those damages with reasonable probability. Second, Kassab’s unlawful acts defense has been preempted and does not apply—a defense Kassab acknowledged in another case is “no longer good law.” I. BACKGROUND1 Kassab’s campaign of lawsuits and bar grievances against Pohl can only be described as a failure. Kassab facilitated the filing of seven separate grievances with the Texas State Bar and four law… |
| 35 | 2022-09-12 | RSP | Pohl | Pohl’s response to Kassab no-evid MSJ | Plaintiffs' Response in Opposition to No-Evidence Motions for Summary Judgment Filed by Kassab and Nicholson Defendants — Pohl presents extensive evidence supporting all three claims (conspiracy, conversion, TUTSA) and rebuts defendants' challenges to ownership, protection, misappropriation, and damages elements | Response to no-evidence MSJs filed by Kassab and Nicholson defendants on August 29, 2022, in the third phase of litigation. Filed September 12, 2022 at 11:26 PM. Pohl incorporates by reference the discussion and evidence from his companion Response in Opposition to the Traditional Motions filed the same day. Filed by Jean C. Frizzell of Reynolds Frizzell LLP. Addressed to the 189th Judicial District Court of Harris County. | MSJ-2 | N/A | Phase 3 | 2022-09-12_RSP_Pohl-Response-to-Kassab-No-Evid-MSJ_FILED.pdf | Deny the no-evidence motions for summary judgment filed by Kassab and Nicholson and allow all issues to be tried by a jury | 9/12/2022 11:26 PM Marilyn Burgess - District Clerk Harris County Envelope No. 68182775 By: Deandra Mosley Filed: 9/12/2022 11:26 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’ RESPONSE IN OPPOSITION TO THE NO EVIDENCE MOTIONS FOR SUMMARY JUDGMENT FILED BY THE KASSAB DEFENDANTSl AND THE NICHOLSON DEFENDANTS Plaintiffs Michael Pohl and Law OfMfice of Michael A. Pohl (collectively “Pohl”) respond in opposition to the No Evidence Motions for Summary Judgment filed by Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C., d/b/a The Kassab Law Firm (collectively “Kassab”) and Tina Nicholson and Baker Nicholson, LLP d/b/a Baker Nicholson Law Firm (collectively, “Nicholson”). Given the overlapping issues in the multiple summary judgment motions before the Court, Pohl also incorpcorates by reference the discussion and evidence included in his Response in Opposition to the Traditional Motions for Summary Judgment Filed by the Kassab Defendants and the Nicholson Defendants that is filed on the same day as this Response. I. FACTUAL BACKGROUND Pohl represented various persons and entities in claims arising from motor vehicle accidents and the British Petroleum Deepwater Horizon oil spill.1 Pohl engaged Precision Marketing Group, LLC (“Precision”) to provide public relations services, to gathker and preserve evidence, and to screen and liaise with Pohl’s clients and prospective clients.2 l While working for Pohl, Precision necessarily gained access to Pohl’s confidential and propcrietary information and property, including trade … |
| 36 | 2022-09-12 | RSP | Pohl | Pohl’s response to Kassab trad MSJ | Plaintiffs' Response in Opposition to Traditional Motions for Summary Judgment Filed by Kassab and Nicholson Defendants — comprehensive 38-page response opposing limitations, unlawful acts doctrine, attorney immunity, judicial proceedings privilege, release, TUTSA protection, ownership, and damages defenses | Response to traditional MSJs filed by Kassab (Aug. 29, 2022) and Nicholson (Amended, Aug. 29, 2022), four years into litigation. Filed September 12, 2022 at 11:55 PM. Incorporates arguments and evidence from companion no-evidence MSJ response filed same day. Filed by Jean C. Frizzell of Reynolds Frizzell LLP. Notes Court previously denied Kassab's first MSJ (limitations, res judicata, attorney immunity) on August 3, 2021. | MSJ-2 | N/A | Phase 3 | 2022-09-12_RSP_Pohl-Response-to-Kassab-Trad-MSJ_FILED.pdf | Deny the traditional motions for summary judgment filed by Kassab and Nicholson in all respects | 9/12/2022 11:55 PM Marilyn Burgess - District Clerk Harris County Envelope No. 68182991 By: Deandra Mosley Filed: 9/12/2022 11:55 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’ RESPONSE IN OPPOSITION TO THE TRADITIONAL MOTIONS FOR SUMMARY JUDGMENT FILED BY THE KASSAB DEFENDANTSl AND THE NICHOLSON DEFENDANTS Plaintiffs Michael Pohl and Law OfMfice of Michael A. Pohl (collectively “Pohl”) respond in opposition to the Traditional Motion for Summary Judgment filed by Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C., d/b/a The Kassab Law Firm (collectively “Kassab”) and the Amended Traditional Motion for Summary Judgment filed by Tina Nicholson and Baker Nicholson, LLP d/b/a Baker Nicholson Law Firm (collectively, “Nicholson,” and together with Kassab, the “Moving Defendants”). c I. INTRODUCTION On June 8, 2021, Kassab moved for traditional summary judgment on the grounds of limitations, res judicata, and attorney immunity. By order dated August 3, 2021, the Court denied Kassab’s motion. Although nothing has changed relative to the facts relating to the defenses of limitations and attorney immunity, Kassab reargues those issues to the Court. Nicholson likewise asserts limitations and immunity defenses. For the same reasons the Court rejected those defenses in Kassab’s original motions, the Court should reject those defenses again here. The Moving Defendants’ assertion of an “illegal acts” defense fails as both a matter of fact and a matter of law. Both Nicholson and Kassab expend countless breathless pakges and submi… |
| 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… |
Advanced export
JSON shape: default, array, newline-delimited, object
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
);