Filing Sections
Data license: Public court records
9 rows where filing_id = 8
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 58 | 8 8 | Rule 47 Statement | Kassab as Counter-Plaintiff seeks monetary relief of more than $1,000,000.00. |
| 59 | 8 8 | Parties | Identifies all parties: Plaintiffs Michael A. Pohl (individual lawyer residing in Colorado) and Law Offices of Michael A. Pohl. Defendants: Scott Favre and Scott M. Favre PA LLC (Mississippi), Precision Marketing Group LLC (Mississippi), F. Douglas Montague III and Montague Pittman & Varnado PA (Mississippi), Tina Nicholson and Baker Nicholson LLP d/b/a Baker Nicholson Law Firm (Texas). Counter-Plaintiffs: Lance Christopher Kassab (individual) and Lance Christopher Kassab P.C. d/b/a The Kassab Law Firm (Texas professional corporation). |
| 60 | 8 8 | Jurisdiction and Venue | Matter within jurisdictional limits. Venue proper because one or more defendants reside in Harris County and substantial part of acts/omissions occurred there. |
| 61 | 8 8 | General Denial | Generally denies all allegations by Pohl and requests Court require Pohl to carry burden of proof. |
| 62 | 8 8 | Affirmative Defenses | Pleads 17 affirmative defenses: (1) statute of limitations, (2) justification, (3) estoppel, (4) waiver, (5) ratification, (6) release, (7) unclean hands, (8) contribution, (9) failure to mitigate damages, (10) lack of standing, (11) accord and satisfaction, (12) assumption of the risk, (13) illegality/criminal acts, (14) First Amendment, (15) attorney immunity, (16) in pari delicto, (17) res judicata. |
| 63 | 8 8 | Specific Denials | Specifically denies that all conditions precedent regarding Pohl's claims of conversion and theft of trade secrets were performed or occurred prior to Pohl filing suit. |
| 64 | 8 8 | Factual Background and Procedural History | Extensive factual narrative: LCK is a plaintiffs' legal malpractice lawyer. Kassab filed four lawsuits on behalf of over 400 clients against Pohl in four different Harris County courts. Pohl conspired with wife Donalda Pohl, paralegal Jaimes, and three Mississippi runners (Walker, Seymour, Ladner) using sham companies (HH Texas, HH Mississippi, Precision Marketing, GM Team). For BP litigation, runners went door-to-door; Precision paid $300-$400/client; Pohl paid Precision $1,500/client; fee percentage disguised as $1,500/hour rate. For auto accidents, Pohl used Google Alerts; paid up to $7,500/client plus 33% of fees; HH Texas paid HH Mississippi $2,500 per referral. Santana solicited 'dozens and dozens' of cases, paid $5,000/case plus fee percentage, told minorities 'were easier to sign up.' Pohl paid Santana $50,000 cash in 'trick or treat' bags to sign gag agreement; she signed 'under duress.' December 19, 2017 retraction affidavit does not state prior testimony is untrue. Talley solicited 800+ BP claims ($75-$350/client) and 20+ auto cases ($1,400 plus expenses), followed solicitation checklist, carried blank Pohl contracts. Walker indicted and imprisoned. Over 400 clients retained Kassab. Kassab filed grievances per Rule 8.03. Pohl's suit is retaliatory. |
| 65 | 8 8 | Counterclaim for Civil Barratry | Pohl judicially admitted barratry is not legal malpractice; discovery rule does not apply; assignment permitted. Kassab brings counterclaims based on 150 express assignments pursuant to § 16.069. Filed contemporaneously with answer, therefore timely. Remaining counterclaims to be filed by November 7, 2018. |
| 66 | 8 8 | Prayer for Relief | Plaintiffs take nothing; Kassab recovers actual and consequential damages, statutory damages, pre- and post-judgment interest, attorneys' fees and costs, and all other just 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
);