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Filing Sections

553 document sections with headings and summaries

Data license: Public court records

4 rows where filing_id = 47

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section_id ▼ filing_id heading summary
342 47 47 I. Background Recounts procedural history: Kassab filed original RTP Motion May 13, 2022 seeking eight designations. Pohl objected May 31, 2022. Court denied RTP Motion October 31, 2022, finding Pohl's objection 'well taken,' and gave Kassab 14 days to replead. Kassab took 15 days (one day late). Kassab also requested a continuance partly because RTPs had not been designated. All factual allegations in the Supplemental Motion were already in the RTP Motion and Motion to Rule.
343 47 47 II. Comparison of Original (Denied) RTP Motion to Supplemental RTP Motion Paragraph-by-paragraph comparison: First 6.5 pages are word-for-word identical (excluding title references). Facts sections are 100% identical. Paras 15-17 copied from Motion to Rule. Para 18 is the only arguably new content but merely synthesizes prior allegations about Walker/Seymour/Ladner (last clause lightly synthesizes prior factual allegations). Paras 19-25 are copied or paraphrased from original RTP Motion. Para 25 combines text from RTP Motion and Motion to Rule.
344 47 47 III. Discussion Because the Court already found Kassab's allegations deficient and no new factual allegations have been added, the Supplemental RTP Motion should be denied for the same reasons. Pohl incorporates by reference his Original RTP Objection. Court should reject Kassab's 'butterfly effect' theory of proportionate responsibility.
345 47 47 IV. Conclusion Requests the Court deny the Supplemental RTP Motion without leave for Kassab to replead, as Kassab already failed to plead sufficient facts after being granted leave.

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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
);
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