Filing Sections
Data license: Public court records
11 rows where filing_id = 1
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 1 | 1 1 | Summary | Introduces the parties and provides an overview of the claims: Defendants engaged in a scheme to illegally obtain, maintain, and use Pohl's trade secrets and confidential information. Favre and Precision breached a settlement agreement; all Defendants committed conversion and TUTSA violations and engaged in conspiracy. Pohl seeks monetary relief over $1,000,000. |
| 2 | 1 1 | Defendants | Identifies all defendants with their addresses and methods of service. Includes Scott Favre and Scott M. Favre PA, LLC (7044 Stennis Airport Road, Kiln, Mississippi); Precision Marketing Group, LLC (same address); Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm (1214 Elgin Street and 5314 Navarro Street, Houston, Texas); Tina Nicholson and Baker Nicholson, LLP d/b/a Baker Nicholson Law Firm (4306 Yoakum Blvd., Suite 400, Houston, Texas / 1607 Dove Ridge Drive, Katy, Texas); F. Douglas Montague III and Montague Pittman & Varnado, P.A. (525 Main Street, Hattiesburg, Mississippi). |
| 3 | 1 1 | Jurisdiction/Venue | Asserts jurisdiction based on minimum contacts with Texas including engaging in business, committing torts, and residing in Texas. Favre and Precision contracted with Pohl, a Texas resident, to perform the contract in part in Texas. Venue proper in Harris County under Tex. Civ. Prac. & Rem. Code §§ 15.002 and 15.062. |
| 4 | 1 1 | Background | Pohl is a lawyer who represented persons in motor vehicle accident claims and BP Deepwater Horizon oil spill claims. Pohl engaged Precision for public relations, evidence gathering, and client liaison services. Precision gained access to confidential information about up to 10,000 or more clients/prospective clients, including identities, contact information, fee agreements, legal forms, proprietary forms, internal emails, and marketing information. Favre, Precision, and Nicholson stole physical copies and computers, misappropriated electronic data. Favre secretly sold the stolen information to Kassab and Montague for $250,000 cash plus substantial bonuses. Kassab and Montague knew the information was stolen. Kassab used it to solicit Pohl's clients to bring barratry and other cases against Pohl. A prior federal lawsuit (No. 1:14-cv-381-KS-JCG, Southern District of Mississippi) was resolved by a Confidential Settlement Agreement in late April/early May 2017. The Settlement Agreement required return of all documents and deletion of all ESI. Nicholson simultaneously served as counsel for Favre/Precision in the settlement and co-counsel with Kassab/Montague in claims against Pohl. |
| 5 | 1 1 | Count One: Breach of Contract (Against Favre And Precision) | Pohl timely and fully performed the Settlement Agreement. Favre and Precision breached by causing claims and legal actions to be filed against Pohl, assisting Kassab and co-counsel in pursuing claims, failing to return required information (including information previously provided to Kassab or Montague), and failing to permanently delete electronically-stored information. |
| 6 | 1 1 | Count Two: Conversion (Against All Defendants) | Favre, Precision, and Nicholson wrongfully assumed and exercised dominion and control over Pohl's property by stealing confidential information. Kassab and Montague wrongfully exercised dominion and control by knowingly purchasing stolen information. All Defendants wrongfully maintained and used the stolen information in contravention of Pohl's ownership rights. |
| 7 | 1 1 | Count Three: Violation of TUTSA (Against All Defendants) | Pohl maintained client information as confidential trade secrets with independent economic value, taking substantial measures to maintain confidentiality. Favre, Precision, and Nicholson willfully and maliciously misappropriated trade secrets through theft (§ 134A.002(2), (3)(A)), disclosed them to Kassab and Montague without consent (§ 134A.002(3)(B)), and all Defendants used them without consent (§ 134A.002(3)(B)). |
| 8 | 1 1 | Count Four: Civil Conspiracy (Against All Defendants) | All Defendants acted in combination with the agreed object of misappropriating Pohl's trade secrets and converting Pohl's property, each committing overt acts toward the unlawful misappropriation that proximately caused damages. |
| 9 | 1 1 | Damages | Seeks actual damages within jurisdictional limits, injunctive relief under TUTSA § 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-judgment and post-judgment interest. |
| 10 | 1 1 | Trial by Jury | Pohl requests trial by jury and tenders the appropriate jury fee. |
| 11 | 1 1 | Conclusion | Requests judgment in Pohl's favor against all Defendants on all counts and all other legal and equitable relief. |
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CREATE TABLE filing_sections (
section_id INTEGER PRIMARY KEY AUTOINCREMENT,
filing_id INTEGER REFERENCES filings(filing_id),
heading TEXT,
summary TEXT
);