Filing Sections
Data license: Public court records
4 rows where filing_id = 21
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 158 | 21 21 | I. Verified Denials | Pursuant to Rules 93(1) and 93(2) of the Texas Rules of Civil Procedure, Pohl denies that Kassab has legal capacity to sue or recover in the capacity in which he sued. Kassab purports to assert barratry claims assigned to him by his clients. Such assignments of barratry claims (whether complete or partial) are void, and Kassab both lacks legal capacity to sue and to recover. Pohl's Verification is attached as Exhibit A. |
| 159 | 21 21 | II. Answer | Pursuant to Rule 92, Pohl generally denies all allegations in Kassab's Counterclaim and demands strict proof. Pleads eight affirmative defenses: (i) statute of limitations, (ii) laches, (iii) lack of standing, (iv) illegality, (v) res judicata, (vi) estoppel, (vii) failure to mitigate, and (viii) waiver. |
| 160 | 21 21 | III. Special Exceptions | Pohl specially excepts to the counterclaim on grounds of obscurity and lack of fair notice. Argues Kassab is more concerned with attacking Pohl than articulating the basis of his claims. Kassab does not identify the specific cause of action, the original owners of the assigned claims, or any facts giving rise to the barratry counterclaim. The 'Factual Background' section leads up to Kassab stating over 400 clients contacted the firm and filed lawsuits in four Harris County courts — if those facts give rise to the counterclaim, it raises questions about whether these are the same claims as those asserted in Brumfield and Gandy prior litigation, which would implicate res judicata. |
| 161 | 21 21 | IV. Conclusion | Requests the Court render judgment that Kassab take nothing; dismiss Kassab's counterclaim for barratry on its merits; and grant all other relief to which Pohl 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
);