filing_sections: 286

553 document sections with headings and summaries

Data license: Public court records

This data as json

section_id	filing_id	heading	summary
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.