Filing Sections
Data license: Public court records
10 rows where filing_id = 20
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 148 | 20 20 | Rule 47 Statement | Kassab, as Counter-Plaintiff, seeks monetary relief of more than $1,000,000.00. |
| 149 | 20 20 | Parties | Identifies all parties. Plaintiff Michael A. Pohl is an individual lawyer residing in Colorado. Plaintiff Law Offices of Michael A. Pohl is a law firm set up for practice in various states including Texas. Defendants include Scott Favre (Mississippi), Scott M. Favre PA LLC, Precision Marketing Group LLC, F. Douglas Montague III (Mississippi), Montague Pittman & Varnado PA, Tina Nicholson (Texas), Baker Nicholson LLP (Texas). Defendants/Counter-Plaintiffs are Lance Christopher Kassab (Texas) and Lance Christopher Kassab P.C. d/b/a The Kassab Law Firm. |
| 150 | 20 20 | Jurisdiction and Venue | Matter within jurisdictional limits. Venue proper because one or more defendants reside in Harris County and a substantial part of the acts/omissions occurred there. |
| 151 | 20 20 | General Denial | Kassab generally denies all allegations made by Pohl and requests the court require Pohl to carry the burden of proof on all allegations. |
| 152 | 20 20 | Affirmative Defenses | Kassab pleads 18 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 the risk, (13) illegality/criminal acts, (14) First Amendment, (15) attorney immunity, (16) in pari delicto, (17) res judicata, (18) defect of parties. |
| 153 | 20 20 | Specific Denials | Kassab specifically denies that all conditions precedent regarding Pohl's claims of conversion and theft of trade secrets were performed or occurred prior to Pohl's filing of suit. |
| 154 | 20 20 | Factual Background and Procedural History | Extensive factual recitation alleging Pohl engaged in systematic barratry through runners (Walker, Seymour, Ladner) who solicited clients through sham entities including Precision Marketing Group, Helping Hands companies, and GM Settlement Verification Team. Details testimony from runners Magdalena Santana and Kenneth Talley about illegal solicitation of auto accident victims and BP oil spill claimants. For BP claims, runners paid $300-$400 per client, Pohl paid Precision $1,500 per client plus percentage of fees disguised as $1,500/hour rate. For auto accidents, Pohl paid $7,500 per client plus 33% of fees. HH Texas paid HH Mississippi $2,500 per referral. Pohl sent Jaimes to Florida with $50,000 cash in bags marked 'trick or treat' to buy Santana's silence. Walker received over $5 million in 'barratry pass-through money.' Walker indicted and sent to prison. Over 400 illegally solicited clients contacted Kassab for representation. Kassab filed four lawsuits and grievances under Rule 8.03. Pohl's suit alleged to be retaliatory. |
| 155 | 20 20 | Counterclaim for Civil Barratry | Kassab asserts counterclaims for civil barratry based on express assignments of interest from 242 claimants. Pohl judicially admitted that barratry is not legal malpractice and the Discovery Rule does not apply to barratry claims. Relies on Tex. Civ. Prac. & Rem. Code § 16.069 to revive otherwise time-barred claims, arguing the counterclaims arise from the same transaction or occurrence as Pohl's suit and were filed within 30 days of the answer deadline. |
| 156 | 20 20 | Designation of Responsible Third Parties | Designates George W. (Billy) Shepherd, Scott Walker, Steve Seymour, Kirk Ladner, Dona Pohl, Edgar Jaimes, Ken Talley, Magdalena Santana, HH Texas, HH Mississippi (Helping Hands Group LLC and Helping Hands Financial LLC), and GM Settlement Verification Team LLC as responsible third parties. Shepherd represented Pohl in Federal Litigation and knew Favre had given documents to third parties including Kassab prior to negotiating settlement — may have intentionally failed to protect Pohl's interest to secure future lucrative employment. Walker, Seymour, and Ladner owned and transferred all assets/property to Favre. Third parties routinely placed Pohl's alleged trade secrets in the public domain. |
| 157 | 20 20 | Prayer for Relief | Requests that Pohl recover nothing; seeks actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other relief to which Kassab may be entitled. |
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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
);