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24 2022-02-04 RPL Pohl Pohl’s reply ISO MSJ on counterclaims Plaintiffs' Reply in Support of Their Motion for Summary Judgment on Defendants' Counterclaims for Civil Barratry Pohl's reply brief supporting his MSJ on Kassab's barratry counterclaims, filed February 4, 2022. This is the final brief in the CC-1 motion chain before the court's ruling (which ultimately granted Pohl's motion). Attorney: Jean C. Frizzell of Reynolds Frizzell LLP. CC-1 N/A Phase 2 2022-02-04_RPL_Pohl-Reply-ISO-MSJ-on-CC_FILED.pdf Grant summary judgment dismissing Kassab's counterclaims for civil barratry 2/4/2022 3:45 PM Marilyn Burgess - District Clerk Harris County Envelope No. 61466983 By: Deandra Mosley Filed: 2/4/2022 3:45 PM CAUSE NO. 2018-58419 MICHAEL A. POHL AND LAW OFFICE OF § IN THE DISTRICT COURT OF MICHAEL A. POHL, PLLC, § Plaintiffs, § V. § k § e SCOTT FAVRE and SCOTT M. FAVRE PA, § C l LLC; PRECISION MARKETING GROUP, § HARRIS COUNTY, TEXAS LLC; LANCE CHRISTOPHER KASSAB and § c LANCE CHRISTOPHER KASSAB, P.C. d/b/a § r THE KASSAB LAW FIRM; TINA § s NICHOLSON and BAKER NICHOLSON, § LLP d/b/a BAKER NICHOLSON LAW § s FIRM; and DOUGLAS MONTAGUE III and § s MONTAGUE PITTMAN & VARNADO, P.A., § Defendants. § r189TH JUDICIAL DISTRICT PLAINTIFFS’ REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS’ COUNTERCLAIMS Plaintiffs Michael Pohl and Law Officae of Michael A. Pohl (collectively “Pohl”) file this Reply in Support of Their Motion for Summary Judgment on Defendants’ Counterclaims for Civil Barratry. e In his Response to Plfaintiffs’ Motion (the “Response”) Kassab admits that the Assignments1 underlying hisy counterclaims were shams that altered nothing about the ownership of the claims and wereC made explicitly for the purpose of circumventing the statute of limitations and fomenting otherwise barred litigation. See Response, at 6 (“Seeing Pohl’s retaliatory suit as a means to potenftfially revive the barratry claims dismissed on limitations in Brumfield and Gandy, Kassab aUnd his clients executed 242 Limited Assignments.”); see also Declaration of Lance Kassab ¶ 12, Ex. 5 to the Response (after purported “assignment,” clients retained 60% interest in claims and Kassab retained 40% contingent fee interest). These admissions demonstrate the 1 Terms defined in Plaintiffs’ Motion carry the same meaning in this Reply. invalidity of the Assignments and therefore the Counterclaims. In addition to effectively admitting that the Assignments are shams, Kassab’s Response fails to rebut any of the other bases on which Pohl moved for summary judgment. The Court can resolve Pohl’s Motion based on a straightforward applicationk of res judicata, as Kassab freely admits that he is asserting the very same claims that are subjectl to final judgments. Furthermore, even if they were not barred by res judicata, Kassab’s claims cdo not meet the statutory elements for revival and are themselves barred by limitations. Fsinally, the invalidity of the Assignments only further supports the conclusion that summarsy judgment on Kassab’s claims is proper. I. Res judicata applies and is dispositive of Kassab’s counterclaims. Kassab has confirmed that his counterclaims are the same claims that were resolved by prior final judgments on the merits. See Response, at 6 (confirming that Assignments were for the claims “dismissed on limitations in Brumfield and Gandy”). Res judicata applies to such claims, and the prior judgments dismissing thee Barratry Claims on the basis of limitations preclude Kassab from re-litigating the same claimsf in this lawsuit. Kassab’s sole argumyent against res judicata is a purported “change in material facts” that prevents the applicatioCn of res judicata. See id. at 8. But Kassab supplies no legal support for his argument that a chaange in facts, like an assignment, has any impact on res judicata. Despite the dispositive natufre of the res judicata argument, Kassab devotes just over a single page of his 27- page ResUponse and cites to two cases to address this issue. See id. at 8–9. The two cases deal with application of res judicata to a claim that did not exist at the time of a prior judgment. Neither case supports the conclusion that res judicata does not apply to stale claims that were previously dismissed, merely because a party attempted to circumvent the statute of limitations by assigning their claim to be asserted as a revived counterclaim. In Marino v. State Farm Fire & Cas. Ins. Co., the first case Kassab relies on, the Court “addressed the issue of whether res judicata can bar a subsequent suit on a cause of action that was not recognized until after judgment was rendered in the first suit.” 787 S.W.2d 948, 949 (Tex. 1990) (emphasis added). In the first lawsuit between Marino and State Farm, Markino prevailed at trial on a claim for breach of contract based on State Farm’s denial of an insulrance claim. Id. at 948–49. After the judgment, the Texas Supreme Court “recognized a tocrt cause of action for an insurer’s breach of the duty of good faith and fair dealing,” commonsly called a “bad faith” claim. Id. at 949. The Court found that Marino’s “bad faith” claim, assserted in the second lawsuit, was not barred by res judicata, because it “was based on rights subsequently acquired, [and] it was not part of his former cause of action.” Id. at 950. Kassab’s other case is City of Lubbock v. Stubbs, 327 S.W.2d 411 (Tex. 1959), which addresses the application of res judicata to a ciaty’s attempt to enjoin Stubbs from violating a zoning ordinance. Stubbs, 327 S.W.2d at 414. In a suit involving a prior ordinance, Stubbs prevailed, permitting him to continue using his eland for specific business purposes. The city then passed an ordinance that zoned his land asf residential. Id. at 413. In the second suit, the city sought to enforce the new zoning ordyinance against Stubbs. Stubbs argued that, like in the first suit, he should be able to contiCnue using his land for purposes he was engaged in prior to the passing of the ordinance. Id. at 414. However, the Court found that res judicata did not apply, in part based on the fact thatf Sftubbs’s “present use” of his land differed in each of the suits and that the city was enforcingU a new ordinance. Id. The application of res judicata to Kassab’s counterclaims is not analogous to the situations presented in Marino and Stubbs. Kassab’s Barratry Claims not only existed at the time of the prior final judgments on the merits, the prior judgments apply to the same claims Kassab attempts to assert here. See Response, at 8 (acknowledging that “the prior judgments in Brumfield and Gandy concluded” that “the barratry claims were barred by the statute of limitations”). Courts citing to the Marino and Stubbs cases have properly focused on the existence of a claim and whether it was a “a claim that was raised or that could have been raised in the first action.” Hernakndez v. Del Ray Chem. Intern., Inc., 56 S.W.3d 112, 116 (Tex. App.—Houston [14th Dist.] 200l1, no pet.). Kassab is incorrect that his strategic use of assignments combinecd with section 16.069 of the Civil Practice and Remedies Code allow him to not only avoid tshe proper application of the statute of limitations, but also to avoid the effects of res judicatas. Because the Assignors’ Barratry Claims are the subjects of final judgments, and Kassab is in privity with the Assignors, res judicata applies and prevents Kassab from recovering on his counterclaims. The Court should grant Pohl’s Motion and dismiss Kassab’s Barratry Claims. II. Kassab’s counterclaims are not reavived and are thus barred by limitations. Kassab’s counterclaims for civil barratry are barred by limitations because they accrued more than four years before Kassabe filed the counterclaims. Kassab does not dispute that the underlying Barratry Claims are bafrred by limitations or that his claims are governed by a four-year statute of limitations. See geynerally Response. Instead, Kassab argues that section 16.069 of the Civil Practice and RemCedies Code revives claims purportedly assigned to him. Kassab’s three arguments in responase to Pohl’s Motion do not demonstrate that section 16.069 applies. A. Pfohl’s claims against the Defendants arise of out of a different transaction or occurrence than Kassab’s assigned Barratry Claims. Kassab selectively quotes the standard for determining if section 16.069 applies and misconstrues what facts are relevant to the claims and counterclaims in this lawsuit. See Response, at 10–14. One reason that section 16.069 does not apply is because Kassab cannot show that “[t]he essential facts on which the counterclaim is based [are] significantly and logically relevant to both claims.” Smith v. Ferguson, 160 S.W.3d 115, 120 (Tex. App.—Dallas 2005, pet. denied). As Pohl stated in his Motion, and as Kassab acknowledged in his Response, courts use a “logical relationship test,” when determining whether counterclaims arise oukt of the same transaction or occurrence. See Motion, at 9; see also Response at 10. Howevler, Kassab fails to acknowledge that his own cases state that this test “is met when the same cfacts, which may or may not be disputed, are significant and logically relevant to both claimss.” Commint Tech. Services, Inc. v. Quickel, 314 S.W.3d 646, 653 (Tex. App.—Houston [14sth Dist.] 2010, no pet.) (emphasis added); see generally Response (not using the term “significant” to discuss application of section 16.069). Pohl asserts claims for theft of trade secrets and conversion relating to the Defendants’ theft and misuse of Pohl’s stolen client files anad information. Kassab argues that his counterclaims arise out of the same transaction or occurrence as Pohl’s claims because: “The facts relevant to determining whether Precision gaineed access to Pohl’s confidential information while ‘liaising’ with prospective clients are alsof relevant to determining whether the ‘liaising’ conducted by Precision – at Pohl’s directioyn – amounted to unlawful barratry.” See Response, at 11. Without ever explaining why, KCassab asserts that Pohl’s claims “depend on the manner in which Precision worked for Pohl to procure client contact information.” See id. at 13. Kassab is wrong. “[D]etefrfmining whether Precision gained access to Pohl’s confidential information while ‘liaising’U with prospective clients” is in no way “significant and logically relevant” to Pohl’s claims for conversion and theft of trade secrets against Kassab. Id. at 11; see also Pohl’s First Amended Petition, at 5–12 (describing the factual bases for Pohl’s claims). It does not matter at all to Pohl’s claims whether the information Precision stole and sold was acquired during proper “liaising” or if it was acquired doing alleged barratrous activity. What matters are the facts underlying Kassab’s 2016 purchase and subsequent use of Pohl’s stolen property. Because Kassab’s counterclaims do not arise out of the same transaction or occurrence as Pohl’s claims, section 16.069 does not apply. k B. Kassab did not provide fair notice of valid counterclaimCs lwithin the 30-day period required under section 16.069.  It is undisputed that a counterclaim that does not provide fair nortiice of the facts giving rise to the claims does not satisfy the requirement to assert a counterDclaim within the 30-day period prescribed by section 16.069. See Response, at 14–18 (not dissputing this rule). Instead, Kassab simply asserts that he met this requirement because he argures that his “pleading met that fair notice standard.” See id. at 18. His pleadings demonstrate otherwise. Kassab admits that “fair notice” requires thlat a party be able to “ascertain from the pleading the nature, basic issues, and the type of evidMence that might be relevant to the controversy.” Id. at 17 (quoting Low v. Henry, 221 S.W.3d 6o09, 612 (Tex. 2007)). However, Kassab does not explain how Pohl could understand the natucre, issues, and types of evidence relevant to the barratry claims when Pohl did not know who he was alleged to have committed barratry against. Instead, Kassab argues that even less fair notice was provided by a party in a case cited by Pohl—seeming to suggest that he merely needed to distinguish the facts of that case from the facts in this lawsuit. See id. at 14–17. c However, the distinguishing facts Kassab points out do nothing to change that he was obligated to provide fair notice to Pohl of the bases and nature of his counterclaims. The Court can decide this issue with ease. The question is whether Pohl had “fair notice” of Kassab’s barratry counterclaims when Kassab did not provide the means for Pohl to determine who he was alleged to have committed barratry against. Kassab argues that there is fair notice because of the seven pages of “facts” included in Kassab’s Third Amended Counterclaim. See id. at 16. Even if those “facts” were part of the counterclaims,2 they did not inform Pohl who he allegedly improperly solicited and committed barratry against. Pohl could not understand the nature, issues, and types of evidence relevant to the counterclaims without knowing who he was alleged to have committed barratry against. k Kassab’s allegation of unspecified “assigned barratry claims”—withoult any indication of who assigned the claims—does not provide “fair notice” of the claims uncder Texas law.3 Kassab did not assert his counterclaims within the required 30-day periods to revive claims barred by limitations, and this Court should dismiss Kassab’s counterclaimss. C. Kassab has no response to the reasoning demonstrating that the Barratry Claims assigned to Kassab after this lawrsuit was filed cannot be revived. In his Motion, Pohl argued that section 16.069 cannot revive claims assigned after a lawsuit to circumvent the otherwise applicable statute lof limitations. He noted that courts apply the provisions of the Code Construction Act whMen construing section 16.069, and thus, its purpose and the consequences of a particular interpreotation are relevant to determining if section 16.069 should apply. See Motion, at 13 (citations comitted). Instead of challenging the legal principles that led to the reasoning of the cases cited by Pohl, Kassab argues simply that the cases are factually distinguishable and sought different forms of relief. See Response, at 18–19. Kassab does not explain why the Court, in considering the object and purposce of section 16.069, should construe the statute to apply in circumstances when a defendant engages in gamesmanship to attempt “to circumvent limitations by relying on section 2 That factual discussion was not incorporated into Kassab’s counterclaim and appeared to be an explanation for why Kassab believes the lawsuit was retaliatory, not the basis of the counterclaims. See Kassab’s Counterclaim, at 11–12. 3 Kassab’s suggestion that Pohl somehow should not be able to assert this argument because “Pohl could have obtained a hearing on his special exceptions if he actually believed that Kassab’s pleadings were deficient,” misses the point. See Response, at 18. The issue for Kassab is whether he gave fair notice of his counterclaim within the required 30- day period. It does not matter if subsequent to that, Pohl fails to secure a ruling on potential special exceptions. 16.069.” See Ball v. SBC Communications, Inc., 04-02-00702-CV, 2003 WL 21467219, at *5 (Tex. App.—San Antonio June 25, 2003, pet. denied). The Court should not allow Kassab to use section 16.069 to revive claims that he did not even own until after this lawsuit was filed. The object and purpose of section 1k6.069 would be frustrated by permitting its application to these claims. l III. Kassab’s arguments regarding the validity of the Assignmcents of the Barratry Claims fail and do not address the substance of Pohl’s argruments. In his Motion, Pohl argued that the Assignments of the BaDrratry Claims are void because they (1) are impermissible assignments of statutory punitive cslaims, and (2) violate public policy by acting as an improperly obtained, transparent device to ravoid limitations and increase litigation. See Motion, at 14. Kassab’s lead argument in response is that the Assignments are valid because Pohl is estopped from arguing otherwise. Kassabl’s misleading attempt to invoke estoppel and his responses to Pohl’s actual arguments do noMt work. A. Kassab’s invocation of ojudicial estoppel is misleading, and it does not apply. Kassab’s opening and primcary argument regarding the validity of the Assignments is a legally deceptive argument that Pohl should be estopped from arguing they are invalid because he purportedly made an inconpsistent argument in other cases. See Response, at 20 (stating that Pohl “has simultaneously argued to the Texas Supreme Court that the Assignments are valid”). It is unclear why Kasscab would seek to draw this Court’s attention to the fact that while asserting his “assigned” Boarratry Claims in this Court, he simultaneously was representing clients asserting the exact same claims in two appellate proceedings without having notified those courts of the purported assignments. Contrary to Kassab’s arguments, Pohl did not take an inconsistent position in the Texas Supreme Court. Instead, Pohl’s briefing referred to “purported” assignments and notified the Supreme Court that Kassab himself had argued that the Assignments are valid. See Response, Exs. 5A, 5B. Furthermore, even had Pohl taken inconsistent position, he did not prevail on this position, making estoppel inapplicable.4 Kassab was aware that Pohl did not prevail on this alternative argument, kand yet he still makes his estoppel argument, citing to a single case. See id. at 21 (citing lFerguson v. Bldg. Materials Corp. of Am., 295 S.W.3d 642, 643 (Tex. 2009)). However, Fecrguson makes clear that estoppel is not applicable here, because it “precludes a party whso successfully maintains a position in one proceeding from afterwards adopting a clearlys inconsistent position in another proceeding to obtain an unfair advantage.” Ferguson, 295 S.W.3d at 643 (emphasis added). Kassab somehow failed to include the full standard for judicial estoppel, despite it being contained on the same page that he cited. See Response, at 21 (citing to Ferguson, 295 S.W.3d at 643). B. Kassab has no real responase to the fact that the Assignments contain impermissible assignmentsM of statutory punitive claims. In his Response, Kassab does noot address the fact that punitive statutory claims are often not assignable, nor does he address cthe four factors the Texas Supreme Court uses when analyzing the assignability of a statutory cause of action. See Response, at 21–24. Instead, Kassab discusses the assignability of legal malpractice claims—which Pohl did not bring up and which has no relevance to Pohl’s actual arguments—and sets up a straw man of Pohl’s arguments by contending that Pohl relies onc an exception to assignability that is limited to DTPA claims. See id. at 21–22. Kassab contends that Pohl’s arguments regarding the invalidity of an assignment of a civil barratry claim fail because of “the simple fact that a civil barratry claim is not a DTPA claim.” 4 See January 28, 2022 Notices filed Brumfield v. Williamson, No. 21-0563, in The Supreme Court of Texas, and Gandy v. Williamson, No. 21-0564, in The Supreme Court of Texas (denying petitions for review and dismissing Pohl’s Motions to Dismiss “as moot.”). These records are available at https://search.txcourts.gov/Case.aspx?cn=21- 0563&coa=cossup and https://search.txcourts.gov/Case.aspx?cn=21-0564&coa=cossup. This Court may take judicial notice of these facts. See TEX. R. EVID. 201(b). See id. at 22. This is a non sequitur. While the seminal case on the assignability of statutory claims dealt with assignment of a DTPA claim, its reasoning was explicitly not limited to such claims. See PPG Indus., Inc. v. JMB/Houston Centers Partners Ltd. P’ship, 146 S.W.3d 79, 87 (Tex. 2004) (noting that “the assignability of most claims does not mean all are assignable; exckeptions may be required due to equity and public policy” (footnotes omitted)). l Kassab all but ignores the four factors considered by the Court inc PPG. See Response, at 21–24. Kassab does not address the fact that the legislature knew hsow to make barratry claims assignable, yet the statute is silent. See TEX. GOV’T CODE § 82.s0651. That the legislature did not explicitly provide for assignment “can be significant” and provides the starting point for a court’s analysis. PPG, 146 S.W.3d at 84. Nor does Kassab discuss the purpose of the civil barratry statute, related common-law principles prohibiting assignments of punitive statutory claims, or whether the Assignments may increase litigation. See aPPG, 146 S.W.3d at 83–92; Response, at 23–24. Kassab argues that some of the risks of distortion discussed in PPG are not present here. See Response, at 23–24. However, thee risks of distortion discussed in PPG were not alleged to be present in that case either. See PfPG, 146 S.W.3d at 91–92. The Court instead was concerned about the rule as applied to ya class of claims. Id. The risks of distortion are present for barratry claims as a class. AndC it is clear that assignments made to avoid limitations, “increase” litigation. Because civil barratry claims are personal and punitive in design, and for the other reasons discussed in thfef Motion, the claims are not assignable. Kassab’s attempt to factually distinguish PPG hasU no effect on the rule and reasoning it laid out. This Court should find that the Assignments of the Barratry Claims to Kassab are void and without effect. C. Kassab’s own admissions show that the Assignments violate public policy. Kassab admits that the Assignments were a sham device used as part of an attempt to avoid the application of the statute of limitations. See Response, at 6 (“Seeing Pohl’s retaliatory suit as 10 a means to potentially revive the barratry claims dismissed on limitations in Brumfield and Gandy, Kassab and his clients executed 242 Limited Assignments”). Kassab also describes in his Response how the Assignments have no practical effect and were simply “effectuated in an attempt to salvage the clients’ barratry claims,” and Kassab would return any recovery ikn excess of his contingency fee to the assignors. See id. at 23. These admissions demlonstrate that the Assignments violate public policy, and the Court should decline to enforcce them. As discussed more thoroughly in the Motion, “the assignabislity of most claims does not mean all are assignable; exceptions may be required due to equsity and public policy.” PPG, 146 S.W.3d at 87 (emphasis in original) (footnotes omitted). Courts may look to equitable considerations to invalidate assignments when the assignments “tend to increase or prolong litigation unnecessarily” or when an assignment is used as a “transparent device” to “increase and distort litigation.” See Sw. Bell Tel. Co. v. Mkatg. on Hold Inc., 308 S.W.3d 909, 916 (Tex. 2010); LAKXN Income, Inc. v. TLC Hosp., LLC, 02-20-00415-CV, 2021 WL 3085755, at *5 (Tex. App.— Fort Worth July 22, 2021, no pet.) (cietation omitted). The Assignments Kassabf received undisputedly “tend to increase or prolong litigation unnecessarily” and are admiytted “transparent device[s]” to “increase and distort litigation.” Sw. Bell Tel. Co., 308 S.WC.3d at 916; LAKXN, 2021 WL 3085755, at *5. Kassab’s sole response is simply that “Pohl has the filthiest of hands” and that Pohl should not benefit from any equitable consideration. f fSee Response, at 26. However, Kassab’s overheated statements and citation to a court’s dUiscussion of “the past litigation that led to this suit as it is relevant to the issues being decided now,” are not competent evidence of unclean hands. See Kassab v. Pohl, 612 S.W.3d 571, 574 (Tex. App.—Houston [1st Dist.] 2020, pet. denied); Response, at 26 (citing Kassab v. Pohl). 11 Kassab ignores the fact that the Court must consider both public policy and equitable considerations, and he does not explain why Pohl’s analysis of those considerations is incorrect. Instead Kassab focuses on a side issue, arguing that the Assignments cannot be invalidated even if he did violate Disciplinary Rule 1.08(h). See Response, at 24–26. While his akttempt to argue that the Assignments do not violate Rule 1.08(h) makes little sense, it is worthl noting that Kassab quotes the relevant caselaw in a misleading fashion. Kassab suggests that “ceven if the Assignments are unethical and in violation of Rule 1.08 . . . the Court cannot void tshem.” See Response, at 25– 26 (citing M.A. Mills, P.C. v. Kotts, No. 14-20-00395-CV, 2022s WL 176125, at *8 (Tex. App.— Houston [14th Dist.] Jan. 20, 2022, no pet. h.)). However, Knotts dealt with a different provision of the Rules, and the court explicitly stated: “We previously opined that courts ‘may deem these rules to be an expression of public policy, so that a contract violating them is unenforceable as against public policy,’ but we also said thaat courts ‘are not required to do so.’” Kotts, 2022 WL 176125, at *6 (citations omitted) (emphasis added). Ultimately, whether Kassab oebtained these assignments in violation of the ethical rules is just an additional factor for the Cfourt to consider along with the other public policy and equitable considerations. Kassab is attyempting to use the Assignments to avoid the application of the statute of limitations in a manCner that increases and promotes litigation, rather than curbing it. The sole purpose of the Assignments was to circumvent the statute of limitations and promote further litigation. Assfigfnments that injure the public good such as these should be rejected. U PRAYER For the foregoing reasons, and the reasons stated in Pohl’s Motion, Pohl requests that the Court grant summary judgment dismissing Kassab’s counterclaims. 12 Dated: February 4, 2022 Respectfully submitted, REYNOLDS FRIZZELL LLP By: /s/ Jean C. Frizzell Jean C. Frizzell State Bar No. 07484650 k 1100 Louisiana St., Suite 3500 e Houston, Texas 77002 l Tel. 713.485.7200 Fax 713.485.7250 c jfrizzell@reynoldsfrizzell.rcom Attorney for PlaintifDfs Michael Pohl and Law Office of Michael A. Pohl, PLLC CERTIFICATE OF SERrVICE I hereby certify that a true and correct copy of this document was served on all counsel of record pursuant to the Texas Rules of Civil Procedure on this 4th day of February, 2022. M /s/ Jean C. Frizzell  Jean C. Frizzell 13 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Melissa Hyland on behalf of Jean Frizzell Bar No. 7484650 mhyland@reynoldsfrizzell.com r Envelope ID: 61466983 Status as of 2/4/2022 3:50 PM CST Case Contacts r i Name BarNumber Email TimestampSubmitted Status Jean C.Frizzell jfrizzell@reynoldsfrizzell.com s2/4/2022 3:45:54 PM SENT Todd Taylor ttaylor@jandflaw.com g2/4/2022 3:45:54 PM SENT Scott M.Favre scott@favrepa.com u 2/4/2022 3:45:54 PM SENT Lance Kassab eserve@kassab.law  2/4/2022 3:45:54 PM SENT Murray JFogler mfogler@foglerbrar.cyom 2/4/2022 3:45:54 PM SENT Murray Fogler mfogler@fbfog.caom 2/4/2022 3:45:54 PM SENT Larry Newsom lnewsom@krcl.com 2/4/2022 3:45:54 PM SENT Jason M.Ciofalo jason@cioofalolaw.com 2/4/2022 3:45:54 PM SENT Misty Davis mdavis@reynoldsfrizzell.com 2/4/2022 3:45:54 PM SENT Andrew J. Sarne asafrne@krcl.com 2/4/2022 3:45:54 PM SENT Kathryn Laflin KLaflin@KRCL.com 2/4/2022 3:45:54 PM SENT Dale Jefferson 10607900pjefferson@mdjwlaw.com 2/4/2022 3:45:54 PM SENT Raul Herman Suazo 24003C021 suazo@mdjwlaw.com 2/4/2022 3:45:54 PM SENT Kevin Graham Cain 24a01l2371 cain@mdjwlaw.com 2/4/2022 3:45:54 PM SENT Harris Wells hwells@reynoldsfrizzell.com 2/4/2022 3:45:54 PM SENT Solace Southwicko ssouthwick@reynoldsfrizzell.com 2/4/2022 3:45:54 PM SENT E. MarieJamisUon jamison@wrightclosebarger.com 2/4/2022 3:45:54 PM SENT Jessica Z.Barger barger@wrightclosebarger.com 2/4/2022 3:45:54 PM SENT Chris C.Pappas cpappas@krcl.com 2/4/2022 3:45:54 PM SENT Todd Taylor ttaylor@jandflaw.com 2/4/2022 3:45:54 PM SENT David R.Wade lawyerwade@hotmail.com 2/4/2022 3:45:54 PM SENT Felicia Grace fgrace@krcl.com 2/4/2022 3:45:54 PM SENT

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