section_id,filing_id,heading,summary
342,47,I. Background,"Recounts procedural history: Kassab filed original RTP Motion May 13, 2022 seeking eight designations. Pohl objected May 31, 2022. Court denied RTP Motion October 31, 2022, finding Pohl's objection 'well taken,' and gave Kassab 14 days to replead. Kassab took 15 days (one day late). Kassab also requested a continuance partly because RTPs had not been designated. All factual allegations in the Supplemental Motion were already in the RTP Motion and Motion to Rule."
343,47,II. Comparison of Original (Denied) RTP Motion to Supplemental RTP Motion,Paragraph-by-paragraph comparison: First 6.5 pages are word-for-word identical (excluding title references). Facts sections are 100% identical. Paras 15-17 copied from Motion to Rule. Para 18 is the only arguably new content but merely synthesizes prior allegations about Walker/Seymour/Ladner (last clause lightly synthesizes prior factual allegations). Paras 19-25 are copied or paraphrased from original RTP Motion. Para 25 combines text from RTP Motion and Motion to Rule.
344,47,III. Discussion,"Because the Court already found Kassab's allegations deficient and no new factual allegations have been added, the Supplemental RTP Motion should be denied for the same reasons. Pohl incorporates by reference his Original RTP Objection. Court should reject Kassab's 'butterfly effect' theory of proportionate responsibility."
345,47,IV. Conclusion,"Requests the Court deny the Supplemental RTP Motion without leave for Kassab to replead, as Kassab already failed to plead sufficient facts after being granted leave."