section_id,filing_id,heading,summary
393,51,Summary,"Explains that Pohl initially sued Favre and Precision as co-conspirators with Kassab, alleging they were all part of a scheme to illegally obtain and use Pohl's trade secrets. On November 21, 2022, Pohl inexplicably nonsuited Favre and Precision. Kassab seeks to designate them as responsible third parties since they are alleged to have caused or contributed to the harm. Motion is timely because no trial date is set."
394,51,Background,"Details how Pohl hired Precision (owned by Walker and Ladner) to provide 'public relations services' and solicit clients, which was revealed to be barratry when Walker/Precision sued Pohl in Mississippi for nonpayment. Pohl agreed to pay Precision a percentage of attorney fees in violation of Rule 5.04(a). Favre purchased Precision and testified its marketing lists were solely Precision's work product. Favre provided information to Kassab, who sent State Bar-approved advertisement letters. Hundreds responded; Kassab filed four barratry lawsuits on behalf of 400+ clients. Pohl then filed this retaliatory lawsuit alleging Favre/Precision misappropriated and sold trade secrets to Kassab."
395,51,Argument,"Under § 33.004(a), since no trial date is set, the motion is timely. Court must grant leave under § 33.004(f) unless objecting party establishes insufficient facts. Pohl's own pleadings establish Favre and Precision's potential responsibility as 'responsible third parties' under § 33.011(6) — Pohl alleged they caused or contributed to the harm through misappropriation and sale of trade secrets."
396,51,Conclusion & Prayer,"Requests the court grant leave to designate Favre, Scott M. Favre PA, LLC, and Precision Marketing Group, LLC as responsible third parties."