section_id,filing_id,heading,summary
103,14,Summary (paragraphs 1-7),"Overview of claims: Defendants engaged in a scheme to illegally obtain, maintain, and use trade secrets and confidential information belonging to Pohl. Favre and Precision breached a settlement agreement. All defendants committed conversion and TUTSA violations, plus conspiracy. Pohl seeks monetary relief over $1,000,000. All conditions precedent have been performed or have occurred."
104,14,Defendants (paragraphs 8-16),"Identifies all defendants with service information: Scott Favre and Scott M. Favre PA, LLC (Mississippi); Precision Marketing Group, LLC (Mississippi); Lance Christopher Kassab and Kassab Law Firm (Houston, Texas — 1214 Elgin Street); Tina Nicholson and Baker Nicholson LLP (Houston, Texas — 4306 Yoakum Blvd., Suite 400); F. Douglas Montague III and Montague Pittman & Varnado, P.A. (Mississippi — 525 Main Street, Hattiesburg)."
105,14,Jurisdiction/Venue (paragraphs 17-18),"Asserts jurisdiction based on defendants' minimum contacts with Texas including engaging in business, committing torts, and residing in Texas. Favre and Precision contracted with Pohl, a Texas resident, for performance in Texas. Venue proper in Harris County under Tex. Civ. Prac. & Rem. Code sections 15.002 and 15.062."
106,14,Background (paragraphs 19-34),"Pohl represented persons in motor vehicle accidents and BP Deepwater Horizon oil spill claims. Precision was hired for public relations, evidence gathering, and client liaison. Precision gained access to confidential information on up to 10,000+ clients/prospective clients including attorney-client fee agreements, client compilations, confidential communications, specialized legal forms, proprietary forms, internal emails, and marketing information. Favre and Precision stole physical copies, computers, and electronic data. With Nicholson's knowing assistance, they secretly sold the information to Kassab and Montague for $250,000 plus bonuses. Kassab admitted in a sworn affidavit receiving the information. The purchase agreement includes an indemnity clause. Nicholson was motivated by her own business interest — the transaction gave her a co-counsel relationship with Kassab. A federal lawsuit in Mississippi was resolved via Confidential Settlement Agreement (late April/early May 2017) requiring return of all documents and deletion of electronic copies, and barring Favre/Precision from causing claims against Pohl. Nicholson simultaneously represented Favre/Precision in settlement and was Kassab/Montague's co-counsel."
107,14,Count One: Breach of Contract (paragraph 35) — Against Favre and Precision,"Favre and Precision breached the Settlement Agreement by assisting in the manufacture and prosecution of claims against Pohl, causing claims to be made and filed against Pohl, and assisting Kassab and co-counsel in pursuing claims."
108,14,Count Two: Conversion (paragraphs 36-38) — Against All Defendants,"Favre, Precision, and Nicholson wrongfully assumed dominion over Pohl's property by selling it. Kassab and Montague wrongfully exercised dominion by knowingly purchasing stolen property. All defendants wrongfully maintained and used the stolen information. Damages exceed $250,000 (the purchase price)."
109,14,Count Three: Violation of TUTSA (paragraphs 39-42) — Against All Defendants,"Pohl's client information constituted trade secrets with independent economic value exceeding $250,000. Pohl took substantial measures to maintain confidentiality and obtained assurances from Precision. Defendants willfully and maliciously misappropriated through theft (§ 134A.002(2), (3)(A)), disclosure via sale without consent (§ 134A.002(3)(B)), and unauthorized use (§ 134A.002(3)(B))."
110,14,Count Four: Civil Conspiracy (paragraph 43) — Against All Defendants,"Each defendant acted in combination with agreed object of misappropriating Pohl's trade secrets and converting his property, committing overt unlawful acts that proximately caused damages."
111,14,Damages (paragraphs 44-48),"Seeks actual damages, injunctive relief under § 134A.003, exemplary damages under §§ 41.001 et seq. and 134A.004(b), attorney's fees under §§ 38.001 et seq. and 134A.005, and pre- and post-judgment interest."