Filing Sections

553 document sections with headings and summaries

Data license: Public court records

3 rows where filing_id = 13

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section_id ▼ filing_id heading summary
100 13 13 Introduction / Incorporation of Favre Arguments Kassab files this supplement to incorporate paragraphs 35-42 and exhibits from Favre/Precision's Motion to Dismiss. The incorporated arguments purportedly show that Pohl's claims were filed far beyond the statute of limitations. Argues not only a preponderance but a 'plethora of evidence' establishing the limitations defense under TCPA § 27.005(d).
101 13 13 Retaliation Argument Kassab argues this is a retaliatory lawsuit filed by Pohl in response to Kassab representing more than 400 clients against Pohl in four separate lawsuits. Notes Pohl is a 'seasoned lawyer' and his counsel Jean Frizzell holds himself out as a 'Top 100 Super Lawyer.' Contends it is 'unfathomable' that they could be so incompetent as to not know the claims were 'dead on arrival when filed,' so the only plausible explanation is retaliation.
102 13 13 Conclusion & Prayer Requests dismissal of Pohl's claims with prejudice, attorney's fees as previously requested, and sanctions of a minimum of $50,000 against Pohl and his counsel Frizzell to deter future frivolous and retaliatory filings. Argues failure to sanction would reinforce lawyers to 'harass, create delay, increase the cost of litigation and create conflicts with impunity.'

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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
);