Filing Sections
Data license: Public court records
4 rows where filing_id = 4
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 28 | 4 4 | General Denial | Pursuant to Rule 92, Montague Defendants deny all material allegations in Pohl's Original Petition and any future amended petitions, demanding strict proof by preponderance of the evidence at trial. |
| 29 | 4 4 | Affirmative and Additional Defenses | Montague Defendants assert 12 affirmative defenses in the alternative, subject to their special appearance: (2.1) lack of standing/no duty owed — no attorney-client relationship with Pohl, not party to underlying litigation or settlement, and attorney immunity for referral of cases as traditional legal services; (2.2) failure to state a claim — conspiracy and related torts fail because liability for underlying tort is foreclosed where only link is bald assertion Montague 'knew' information was stolen, citing Frankoff v. Norman; (2.3) comparative responsibility/contributory negligence under Chapter 33, including reduction based on Plaintiffs, other Defendants, settling defendants, and responsible third parties; (2.4) excuse, legal justification, and good faith; (2.5) no legally cognizable damages/failure to mitigate; (2.6) failure to satisfy conditions precedent; (2.7) estoppel; (2.8) waiver; (2.9) unclean hands; (2.10) illegality; (2.11) statute of limitations; (2.12) Chapter 41 limitations on exemplary damages. |
| 30 | 4 4 | Request for Disclosure | Subject to their special appearance, pursuant to Rule 194 of the Texas Rules of Civil Procedure, Montague Defendants request Plaintiffs disclose all information and material described in Rule 194.2 within 30 days of service. |
| 31 | 4 4 | Prayer | Requests the court grant their special appearance or, alternatively, deny all relief against Montague Defendants and render a take-nothing judgment, with costs awarded to 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
);