Filing Sections
Data license: Public court records
7 rows where filing_id = 45
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 324 | 45 45 | Requested Relief (Paras 1-3) | Kassab seeks to add Favre and Precision as additional responsible third parties after Pohl dismissed them November 21, 2022, just 14 days before trial. Good cause exists due to timing of dismissal. Favre and Precision are central to the litigation (purchased all subject material from Walker/Ladner/Seymour), are outside the court's subpoena power, and Kassab has been unable to depose them for over a year. |
| 325 | 45 45 | II. Facts (Paras 4-16) | Substantially identical factual recitation as prior RTP motions and Eighth Amended Answer. Covers barratry operation, BP and auto accident solicitation, Santana and Talley testimony, Mississippi Litigation, Favre's May 2016 purchase of Precision, Kassab's investigation, and Pohl's retaliatory lawsuit. |
| 326 | 45 45 | III. Argument — Legal Standard (Paras 17-19) | Under § 33.004(a), original motion was timely filed May 13, 2022. Good cause exists for this late designation because Pohl dismissed Favre and Precision 14 days before trial. Notice-pleading standard applies per In re CVR Energy. |
| 327 | 45 45 | Argument — Walker, Ladner, Seymour (Paras 20, 22) | These three misappropriated Pohl's alleged trade secrets and sold them to Favre. Pohl testified they attempted to sell his 'accumulated work product.' Walker testified he had legal right to sell all assets to Favre through Precision. |
| 328 | 45 45 | Argument — Favre and Precision (Para 21) | Favre and Precision certified and represented to Kassab that all material and documents given to Kassab were owned by them after purchase from Walker/Ladner/Seymour. Kassab relied on these representations. Thus Kassab could not have misappropriated trade secrets by improper means. |
| 329 | 45 45 | Conclusion (Para 28) | All 10 designated parties (Favre, Precision, Shepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley, Santana) caused or contributed to causing harm. Jury should be permitted to apportion fault. Footnote 8 notes personal jurisdiction not required under 2003 revision of Chapter 33. |
| 330 | 45 45 | Prayer | Requests the Court grant the RTP Motion to Designate Responsible Third Parties 'in addition to the Supplements' and all other appropriate relief. |
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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
);