Filing Sections
Data license: Public court records
10 rows where filing_id = 12
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 90 | 12 12 | Rule 47 Statement | Kassab as Counter-Plaintiff seeks monetary relief of more than $1,000,000.00. |
| 91 | 12 12 | Parties | Same parties identified as in prior answers: Plaintiffs Pohl (Colorado) and Law Offices of Pohl; Defendants Favre/entities (Mississippi), Precision Marketing (Mississippi), Montague/firm (Mississippi), Nicholson/Baker Nicholson (Texas); Counter-Plaintiffs Kassab (individual, Texas) and Kassab P.C. (Texas). |
| 92 | 12 12 | Jurisdiction and Venue | Same jurisdictional and venue allegations — proper in Harris County. |
| 93 | 12 12 | General Denial | Generally denies all allegations and requests Pohl carry his burden of proof. |
| 94 | 12 12 | Affirmative Defenses | Same 17 affirmative defenses: (1) statute of limitations, (2) justification, (3) estoppel, (4) waiver, (5) ratification, (6) release, (7) unclean hands, (8) contribution, (9) failure to mitigate, (10) lack of standing, (11) accord and satisfaction, (12) assumption of risk, (13) illegality/criminal acts, (14) First Amendment, (15) attorney immunity, (16) in pari delicto, (17) res judicata. |
| 95 | 12 12 | Specific Denials | Same specific denial of conditions precedent for conversion and trade secret claims. |
| 96 | 12 12 | Factual Background and Procedural History | Substantively identical to prior answers. Same detailed barratry scheme narrative including runner operations, Santana and Talley testimony, $50,000 gag agreement, Walker imprisonment, over 400 clients, four Harris County lawsuits, grievances. |
| 97 | 12 12 | Counterclaim for Civil Barratry | Expands counterclaims to 242 assigned barratry claimants (up from 235 in Second Amended Answer). Same legal basis: Pohl judicially admitted barratry is not legal malpractice, so assignment is permitted; counterclaims timely under § 16.069 because filed within 30 days of original answer. |
| 98 | 12 12 | Designation of Responsible Third Parties | Enhanced from Second Amended Answer: Shepherd 'further knew that Favre and/or his counsel had given documents to third parties, including Kassab and others prior to negotiating a settlement in the Federal Litigation.' Specifies 'the documents, assets and all other property that Precision owned that were transferred to Favre are the subject of Pohl's lawsuit.' Walker testified he had 'legal right and authority' (adding 'authority') through Precision to transfer. Walker, Seymour, and Ladner transferred 'the subject assets/property of Precision to Favre' (emphasizing Precision's ownership). Same core allegations: Shepherd wholly failed to protect Pohl; malfeasance was either negligent or intentional. |
| 99 | 12 12 | Prayer for Relief | Same prayer: Pohl takes nothing; Kassab recovers actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other just relief against Plaintiffs and/or Third-Party Defendants. |
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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
);