section_id,filing_id,heading,summary
281,37,Declarant Identification (¶¶ 1-3),"David Eric Kassab, born October 20, 1982, business address 1214 Elgin Street, Houston, Texas 77004. Licensed Texas attorney since 2010. Attorney at Lance Christopher Kassab, PC d/b/a The Kassab Law Firm. Represents his uncle and law partner Lance Kassab and the Firm in this suit."
282,37,Barratry Litigation Background (¶¶ 4-5),"David Kassab was counsel in four barratry cases: Berry (filed June 5, 2017, 7 plaintiffs, auto accident claims), Cheatham (filed June 20, 2017, 4 plaintiffs, auto accident claims), Brumfield (filed June 8, 2017, ~272 plaintiffs by July 26, 2017, BP claims against Pohl and Williamson), and Gandy (filed Oct. 16, 2017, ~135 plaintiffs, BP claims). Currently counsel in Cheatham appeal."
283,37,Client Files Received (¶¶ 6-8),"In approximately February 2018, Kassab's office received hundreds of client files from Pohl containing contracts, referral agreements, and communications for Brumfield and Gandy plaintiffs. For Berry and Cheatham cases, Pohl and co-counsel Robert Ammons provided client files through Billy Shepherd (Exhibit A correspondence). Each file necessarily contained documents bearing Pohl's name, letterhead, or logo."
284,37,Pohl's Gandy Affidavit (¶ 7),"In the Gandy case, Pohl filed an affidavit including copies of his contracts with BP clients and an Excel spreadsheet 'Pohl Master List 6673.xlsx.' The affidavit identifies specific plaintiffs and dates they signed fee agreements."
285,37,Discovery Production in Barratry Litigation (¶¶ 9-10),"In Berry and Cheatham cases, Pohl produced several categories including: (a) attorney-client contracts with auto accident clients; (b) service/operating/PR agreements between Pohl and Walker, Ladner, Seymour/Precision; (c) emails about 'signing up' auto accident victims; (d) payment-related emails; (e) banking records; (f) CMV Investigations invoices; (g) text messages with Maxwell and Santana. Separately, Pohl produced ~6,937 pages from Mississippi Litigation including: claimant logs/'Williamson-Pohl Master List' spreadsheets, service agreements, invoices, emails, attorney-client contracts, marketing materials, financial information, bank records, operating/distribution agreements with Santana/Talley, 'BP Settlement Claimant Forms,' contracts for Helping Hands Group/GM Settlement Verification Team/Helping Hands Financing, and Liberis Law Firm attorney-client contracts."
286,37,Discovery Burden in Current Lawsuit (¶¶ 11-15),"Pohl's discovery requests require producing 'Pohl Information' received from any source between April 2012-January 2021. Interrogatories 1-3 require identifying every document bearing Pohl's name with description, acquisition date, termination date, and identity of current possessors. Interrogatory 9 asks for 'Pohl Information' from Mississippi Litigation public records. Requests are overbroad — require re-producing thousands of documents received from Pohl, plus filtering privileged/confidential information. Estimated 405+ hours ($182,250 at $450/hr): 100+ hours for 400+ client files at 15 min each, plus 305+ hours for 61,000+ pages from Cheatham plus 6,000+ Mississippi Litigation pages plus Berry production at 200 pages/hour. Despite burden, Kassab has produced 366,000+ pages in twelve production sets from October 2021 through September 2022, including actual documents from Precision's clients that runners solicited to hire Pohl."