Filing Sections
Data license: Public court records
5 rows where filing_id = 40
This data as json, CSV (advanced)
| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 292 | 40 40 | Objections to Pohl Declaration (Traditional MSJ Response) | Defendants object to approximately 20 paragraphs/statements in Pohl's September 12, 2022 declaration on grounds of: conclusory statements, hearsay, improper lay/expert opinion on legal issues (trade secret status, ownership, possessory interest), vagueness about who at 'Precision' made representations, failure to meet 'clear, positive and direct' standard for interested-witness testimony under Rule 166a(c), and belief statements not constituting competent evidence. Key targeted paragraphs: ¶4 (shared office with contractors), ¶6 (Mississippi attorney review), ¶¶10-11 (Precision representations), ¶12 (ownership/trade secret claims), ¶13 (client list compilation), ¶14 (confidentiality instructions), ¶15 (security measures), ¶16 (denial of barratry), ¶17 (unauthorized practice), ¶18 (fee-sharing denial), ¶20 (attorney consultation), ¶¶21-22 (Precision services), ¶23 (Precision stealing), ¶¶24-25 (theft of property), ¶26 (sanctions), ¶27 (economic value), ¶28 (damages), ¶¶29-30 (no barratry), ¶31 (unawareness of sale), ¶32 (grievance allegations). |
| 293 | 40 40 | Objections to Pohl's Exhibits (Traditional MSJ Response) | Defendants object to State Bar and Board of Disciplinary Appeals dismissal letters (Exhibits F through P, T) as hearsay and irrelevant — grievance outcomes are not res judicata in civil matters (Charles v. Diggs; Tex. R. Disc. P. 17.03). Object to Santana letter (Exhibit R) and audio transcription (Exhibit S) as hearsay. Object to counsel emails/letter (Exhibit Y) as hearsay. |
| 294 | 40 40 | Additional Evidence Offered by Defendants | Defendants attach complete depositions under Rule 107 (optional completeness): Exhibit 1 (Ladner), Exhibit 2 (Seymour), Exhibit 3 (Walker), taken Aug. 29-31, 2022. Highlighted testimony: Ladner — Precision owned marketing/client lists (44-45), Helping Hands decided which firms to refer clients to (55-56, 62-64), Ladner did own research for MVA cases (97, 285-89), Pohl was splitting fees with Precision and contracts were a smokescreen (77-79, 83-85, 94-95, 269-271, 276, 287-288, 398-416, 443), forms/marketing lists belonged to Precision (128-29), Pohl never told Ladner to return documents (133, 173-74), BP claimants were clients of Precision first (214-215), Pohl never told Ladner to keep information confidential (232-35, 264-65, 500-502), spreadsheets/pre-questionnaire forms belonged to Precision (244-245, 262-263), Pohl committed barratry (274-280, 285-86), Helping Hands/GM Verification signed up claimants as own clients (444). Seymour — Pohl never said client lists were confidential (96-98, 147-149, 221-222). Walker — marketing lists were Precision's work product (232-33, 237-242), initial screening forms were Precision's work product (237-242). |
| 295 | 40 40 | Objections to No-Evidence MSJ Response | Defendants incorporate all above objections for the no-evidence response. Additional objections: Exhibit BB (Omnibus Transcript) — hearsay; Exhibit D (grievance documents) — hearsay and irrelevant per Charles v. Diggs and Rule 17.03; Exhibit S (Zavitsanos Report) — hearsay, unsworn; Exhibit T (Pohl Deposition at 115-116) — hearsay regarding what third parties told Nicholson and nonresponsive; Exhibit Y (Pohl Declaration) — same objections as above re trade secret status, ownership, possessory interest. |
| 296 | 40 40 | Conclusion and Prayer | Defendants request the court sustain objections and strike objectionable portions of Pohl Declaration and exhibits. With evidence struck, Pohl has no evidence to support claims, making summary judgment appropriate. |
Advanced export
JSON shape: default, array, newline-delimited, object
CREATE TABLE filing_sections (
section_id INTEGER PRIMARY KEY AUTOINCREMENT,
filing_id INTEGER REFERENCES filings(filing_id),
heading TEXT,
summary TEXT
);