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27 2022-05-13 OA Kassab 5th Amended Answer Kassab's Fifth Amended Answer, Affirmative Defenses, and Counterclaim — live pleading asserting 20 affirmative defenses, general and specific denials, detailed factual background of Pohl's barratry scheme, and counterclaim for civil barratry on behalf of 242 assigned claimants Phase 3 amended pleading filed simultaneously with the Motion to Designate Responsible Third Parties. This is Kassab's fifth iteration of his answer, expanding affirmative defenses and maintaining the barratry counterclaim based on assigned claims from 242 of Pohl's former clients. PLEAD-1 N/A Phase 3 2022-05-13_OA_Kassab-5th-Amended-Answer-CC_FILED.pdf That Pohl recover nothing; that Kassab recover (i) actual and consequential damages, (ii) statutory damages, (iii) pre- and post-judgment interest, (iv) attorneys' fees and costs, and (v) all other just relief on counterclaims 5/13/2022 6:22 PM Marilyn Burgess - District Clerk Harris County Envelope No. 64509093 By: Deandra Mosley Filed: 5/13/2022 6:22 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIrAL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LANCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S FIFTH AMENDED ANSWER, AFFIRMATIVE DEFENSES AND COUNtTERCLAIM TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendants, Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm and files this their Fifth Armended Answer, Affirmative Defenses, and Counterclaim, and would respectfully show the Court as follows; iIl RULE 47a STATEMENT 1. The Kassab Defendantso, in their capacity as Counter-Plaintiffs, seek monetary relief of more than $1,000,000.00. y PARTIES 2. Plaintiff, Michael A. Pohl is an individual lawyer residing in Colorado and is a party herein. c i 3. oPlaintiff, Law Offices of Michael A. Pohl is a law firm set up for the practice of law in various states of the union, including Texas and is a party herein. 4. Defendant, Scott Favre is a nonresident individual residing in Mississippi and is a party herein. 5. Defendant, Scott M. Favre, PA, LLC is a nonresident limited liability company located in Mississippi and is a party herein. 6. Defendant, Precision Marketing Group, LLC is a nonresident limited liability company located in Mississippi and is a party herein. k 7. Defendant, F. Douglas Montague III is a nonresident indilvidual residing in Mississippi. c 8. Defendant, Montague, Pittman & Varnado, PA is sa nonresident professional association located in Mississippi.  9. Defendant, Tina Nicholson is an individual residing in Texas and is a party herein. 10. Defendant, Baker Nicholson, LLP, d/b/a Baker Nicholson Law Firm is a limited liability partnership located in Texas and is a party herein. 11. Defendant, Counter-Plaintiff, Laance Christopher Kassab is an individual residing in Texas and is a party herein.  12. Defendant, Counter-Pelaintiff, Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm is a professional corpofration located in Texas and is a party herein. y III JURISDICTION AND VENUE 13. Thisa matter is within the jurisdictional limits of this Court and Plaintiffs, Counter- Defendants, Mifcihael A. Pohl and Law Offices of Michael A. Pohl (“Pohl”) and Defendants, Counter-Plaintiffs, Lance Christopher Kassab (“LCK”) and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm (“Kassab, P.C.”) (collectively “Kassab”) are subject to the Court’s jurisdiction. Venue is proper in this county because one or more of the defendants are residents of this county and because a substantial part of the acts and/or omissions that form the basis of this suit occurred in this county. GENERAL DENIAL 14. Defendant, Counter-Plaintiff Kassab generally denies all allegations made by Plaintiffs, Counter-Defendants, Michael A. Pohl and Law Offices of Michael A. Pohl, and requests the Court to require Plaintiffs, Counter-Defendants, Michael A. Pohl and Law Oeffices of Michael A. Pohl to carry their burden of proof regarding all allegations against Kassab. V r AFFIRMATIVE DEFENSES 15. Defendant, Counter-Plaintiff Kassab pleads the fsollowing affirmative defenses: 1. Statute of limitations; g 2. Justification; B 3. Estoppel; y 4. Waiver; 5. Ratification; f 6. Release; 7. Unclean hands; O 8. Contribution; 9. Failure to mitigate; 10. Lack ofi standing; 11. Accford and Satisfaction; 12. Assumption of the Risk; 13. Illegality/Criminal Acts; 14. First Amendment; 15. Attorney Immunity; 16. In Pari Delicto; 17. Res Judicata; 18. Defect of Parties; 19. Abandonment; and k 20. Subject of a Valid Contract. l VI c SPECIFIC DENIALS r 16. Defendants, Counter-Plaintiffs specifically deny Dthat all conditions precedent regarding Plaintiffs claims of conversion and theft of trades secrets have been performed or occurred prior to Plaintiffs’ filing of suit against Kassab. r VII FACTUAL BACKGROUND AND PROCEDURAL HISTORY 17. LCK is a lawyer practicing lMaw with The Kassab Law Firm, a law firm in Houston, Texas focusing on plaintiffs’ legal malporactice cases. Kassab filed four lawsuits on behalf of over four hundred clients against Pohl (tche “Harris County Lawsuits”). The main allegations against Pohl are civil barratry and conspiracy to commit barratry, a third-degree felony in Texas. Pohl conspired with his wife, Dopnalda Pohl (“Dona”), his paralegal, Edgar Jaimes (“Jaimes”) and three runners in Mississippi to illegally solicit clients on behalf of Pohl. Dona owns a sham lending company in Texacs icalled Helping Hands Financing, LLC (“HH Texas”). Jaimes rans the day-to- day operationos of HH Texas. The three runners are Scott Walker (“Walker”), Steve Seymour (“Seymour”) and Kirk Ladner (“Ladner”) (collectively “Runners”). The three Runners owned and operated two other sham companies called Helping Hands Group, LLC and Helping Hands Financial, LLC (collectively “HH Mississippi”). The three runners also owned Precision Marketing Group, LLC (“Precision”) which they sold to Scott Favre and/or his companies (collectively “Favre”). The runners had several other business entities from which they operated and concealed their illegal solicitation conspiracy. 18. With regard to the clients obtained in the BP Litigation, Walker, Seymour and Ladner hired other runners to literally go up and down streets in specific locatiokns knocking on doors to solicit clients on behalf of Pohl for lawsuits against British Petroleum.l Walker, Seymore and Ladner, through Precision and on behalf of Pohl, paid these runners acs much as $300-$400 for every potential client they obtained. Pohl paid Precision as muchs as $1,500 for every client Precision obtained and referred to Pohl. Walker, Seymore and Ladner paid the other runners from this amount and pocketed the balance. Pohl also offered and agreed to pay Walker, Seymour and Ladner a percentage of his legal fees once cases settled. This percentage was disguised as an hourly rate of $1,500.00 per hour, but the percentage of the “settlement” payment was never below the agreed percentage. For example, no mattaer how much “hourly” time was actually spent on a case, the agreed upon percentage was always achieved by simply dividing the percentage amount of Pohl’s legal fees by $1,500.00 to caelculate the imaginary number of hours, and then the Runners would submit an invoice for thosef imaginary number of hours. Whether the Runners actually spent five (5) or fifty (50) hours oyn a particular case was not the measure of the “settlement” fees to be paid to the Runners, itC was always the agreed upon percentage of attorney’s fees earned by Pohl regardless of actuala hours spent on a case. 19. Wfith regard to auto accidents, Pohl set up a “Google Alerts” to be notified wheneverU there was a horrific rollover or other type of horrific vehicle crash across the nation. Pohl would then immediately send the alert to the Runners so they could arrange to visit hospitals, homes and funerals to contact the families of the injured in order to solicit them as clients. The Runners would use their sham companies, “Helping Hands” to act as though they were approaching these victims to genuinely help them rather than solicit them. The Runners would falsely tell these victims that they were there to provide money for burial services, food, clothing, lodging, etc. In reality however, the Runners’ contacted these families under these false pretenses with the sole objective of taling advantage of these victims and their families wkhile they were emotionally distraught and not thinking straight in order to lock them into contrlacts which allowed the runners to select a lawyer for the victim. The victims and the family mcembers were encouraged to hire Pohl and told they could not get the money unless they agreed sto hire Pohl. Pohl would pay the Runners as much as $7,500 per client they signed up and Pohl also promised the runners as much as 33% of Pohl’s legal fees on the back end when the case settled. Additionally, HH Texas would pay HH Mississippi $2,500 for every client referred to HH Texas to “loan” money to these victims and their family. Pohl used this procedure as an attempt to put an additional buffer between him and the actual Runners. a 20. Pohl also helped the Runners form another sham entity, the GM Settlement Verification Team (“GM Team”) afteer General Motors, Inc. issued a recall on cars due to faulty ignition switches which effected fthe safe operation of the airbag systems on vehicles. Thus, the GM Team was designed to lyook official as if it was part of General Motors. This conspiracy was to form an official lookCing entity from GM as if GM was wanting to compensate people who had been harmed when aairbags failed to deploy in relation to the ignition recall. In reality, this was just another shafm company used to solicit and trick potential clients into hiring Pohl. Again, Pohl would paUy Walker and Ladner, through their sham entity, the GM Team, a fee for every potential client it referred to Pohl, in addition to a percentage of his attorney’s fees on the back end. 21. Pohl knew what he was doing was illegal barratry. Accordingly, he knowingly formed entities that he perceived would insulate him from liability. In fact, Walker testified that although he and Pohl called it “marketing services” or “marketing money” it was “clear to [him] it was barratry.” In fact, Walker considered himself and his company “a pass-through for barratry money.” All total, Walker, Ladner and Precision received over $5 million in “barratry pass-through money” from Pohl and other lawyers to solicit potential clients with claims, botkh auto-accident victims and those involved in the BP Deepwater Horizon litigation. l 22. One of the runners hired by Pohl and Walker to illegally soclicit clients on behalf of Pohl was Magdalena Santana (“Santana”). In her September 24, 201s6 affidavit, Santana testified that Pohl sent her on “dozens and dozens of car wreck cases all over the country.” Pohl would email Santana the link of news coverage he obtained through Google Alerts depicting an accident and asked her “to go to the victim or the victim’s family and try to get them to sign up with him.” Santana swore under oath that Pohl agreed to pay her “$5,000 per case that [she] signed, plus a percentage of his attorney’s fees.” Santana waas advised by Pohl to “be persistent even if the family ... rejected [her].” Santana was instructed by Pohl to “approach the victims and their families while they were vulnerable, in the emergenecy room, their hospital rooms or at the funerals.” Pohl told Santana that minorities “were espfecially vulnerable since they tended not to know that the law prohibited barratry.” Accoyrding to Pohl, they “were easier to sign up.” 23. Pohl woCuld give Santana “money to give to the victims or their families” but would only give the moneay to the potential client “if they agreed to sign a Pohl representation contract.” Pohl advised Safntana that the money was a “foot in the door” but instructed Santana not to mention anything Uabout hiring a lawyer “until after they agreed to take the money.” “If the client agreed to hire Pohl, then [Santana] was to have the client sign a ‘Helping Hands’ contract.” Santana would then give money to the client “from his own Helping Hands company.” When Santana questioned this, Pohl told Santana that it “was illegal for him to pay [her] directly for cases, and that’s why the money had to go through some company.” 24. Pohl and/or his co-conspirators had Santana retract this affidavit through a December 19, 2017 affidavit. This purported retraction was likely the result of Pohlk paying Santana to retract the first affidavit, which is similar to something Pohl had done in the lpast. In fact, Pohl’s own paralegal, Jaimes, testified that on one occasion Pohl sent him toc Florida with a suitcase containing $50,000 in cash to give to Santana in exchange for her agrseement not to turn Pohl into the authorities. Jaimes testified that Santana would only get the money if she signed a statement agreeing not to mention Pohl’s illegal activity. Jaimes testified that Santana signed the statement and then he gave her the $50,000. 25. Santana’s deposition was even more detailed. Santana testified at her deposition that the statement was an agreement for haer to keep quiet and not charge Pohl with any wrongdoing, criminal or unethical conduct. Santana testified that Pohl paid her $50,000 in cash to sign this statement, which was deliveered by Jaimes in three bags marked “trick or treat.” Very symbolic given that Santana had fbeen tricked by Pohl into soliciting potential clients for him and was now being treated the myoney she claimed was due under their agreement just to stay quiet. Santana reiterated in hCer deposition that if she didn’t sign the gag agreement, she would not have received the moneya from Pohl. Santana attempted to indicate on the agreement that she was receiving $50,00f0 to keep quiet, but Jaimes told her Pohl demanded that she state she only received nominal cUonsideration, like $100. Santana did not write the statement but “just signed it” because she felt she was being “forced to sign” it while “under duress.” 26. Notably, nowhere in Santana’s December 19th affidavit does she state the testimony in her former affidavit is untrue, only that she does not “agree with” it and that the affidavit is not “reliable.” Although Santana states in her December 19th affidavit that her prior affidavit was drafted by a lawyer, Santana testified in her deposition that the September 24th affidavit was created voluntarily with her own “testimony.” Santana testified that, unlike with Pohl, she was not paid and had never been promised any money to provide the testimony in the kSeptember 24th affidavit. Santana reiterated to counsel for Pohl, Billy Shepherd, that she lwas there for her deposition to tell the truth and would not be bullied by his questioning cor his efforts to confuse her. s 27. Regardless, Santana’s sworn deposition testimony confirmed most, if not all of the facts set forth in her initial affidavit and this deposition testimony has never been retracted. Therefore, Santana confirmed that she was hired by Pohl to solicit auto accident cases, the first one being an accident where a woman and her unborn child lost their lives. Santana was instructed by Walker, who was instructed by Pohl, to perasonally visit the mother of the deceased and sign her up to sue the tire manufacturer and, if she succeeded, Pohl would pay her $5,000. Following Walker and Pohl’s instructions, Santeana visited the funeral of the deceased and got the family to feel comfortable with her. Althfough the mother was grieving, Pohl told Santana: “take no prisoners, this is a cut throayt business, you get in there and you do whatever it takes to get this client.” The solicitatioCn was successful after Pohl gave Santana $2,000 to “give to the client to convince her into siagning over with the firm.” 28. f“Coach” Kenneth Talley (“Talley”) was another runner hired by Pohl and Walker who solicUited over 20 auto accident cases for Pohl. Talley has sworn under oath that he was first hired in relation to BP claims to find “folks that lost money due to the oil spill” and “sign them up” and “get a fee for it.” Talley testified that he went to work “knocking on doors” looking for potential claimants for Pohl and his partner in the BP litigation. Talley solicited and signed up more than 800 BP claims for Pohl and his co-conspirators. Talley was paid between $75 and $350 for each BP client he signed up for Pohl and his partners. 29. Talley eventually switched to illegally soliciting auto accident victims for Pohl, “calling on folks that had bad accidents.” Talley recalls that the first client he soklicited for Pohl was in “the hospital in intensive care.” Talley carried with him up to $1,000 lto pay the accident victims to “help them with problems” but paid the potential client only conce they “were signed up.” Talley kept a list of all the auto accident cases he solicited so he scould keep track of the cases that he was due a percentage from Pohl’s attorney’s fees on the back end after the case settled. Talley also followed a checklist that instructed him to, among other things, bring flowers to the initial hospital visit (but to spend no more than $50) and to offer the victims money but to “make sure the funding schedule” from HH Texas “is filled out properly before releasing any cash.” Talley would advise the victims that he had aattorneys who could help them such as Pohl. Talley was paid a fee of $1,400 plus his expenses by Pohl, through Walker and/or one of his sham business entities for any auto accident case he esolicited and referred to Pohl. On some cases, Talley was to receive a portion of the fee paid tfo Helping Hands out of Pohl’s attorney’s fees. Talley discussed with Pohl the “percentage yof settlements” he was to receive from the cases he solicited and referred, and Pohl toldC Talley that the money was being placed in an “escrow account” for him. When asked whethear Pohl knew he was getting paid to “contact vehicle accident victims,” Talley responded, “thef money was coming from Edgar [Jaimes] who worked for him.” And, although his paychUeck was from Walker’s company, “the funding came by way of Edgar [Jaimes].” 30. Talley testified that personally soliciting clients for Pohl became so frequent that he began carrying blank contracts to each solicitation. Talley testified that he never recommended any lawyers other than Pohl. However, Talley never told the clients that he was getting paid to 10 solicit them. Talley would present a contract to the potential client. If the client did not agree to hire Pohl, the clients would not get the money. Talley testified that Jaimes and Dona (the operators of HH Texas) would send him the money. 31. Talley further testified that both he and Pohl knew what they were doking was illegal. In one instance, Talley was “run out of town” while soliciting clients for Pohl. Tlalley testified that during the attempted solicitation he was told by a “lawyer or policeman”c that “it was against the law what [he] was doing.” Talley mentioned this to Pohl and Pohl stold him “you’ve just got to leave...some people you can’t help.”  32. Walker was eventually indicted and sent to prison. Being afraid of where Walker’s indictment might lead, Pohl and his lawyer partners stopped paying Walker and the other runners the illegal fees as Pohl had promised. Therefore, Walker, Seymour, Ladner and Precision filed a lawsuit in Mississippi Federal Court (“Fedearal Litigation”) against Pohl and his law partners claiming they were owed millions of dollars in promised fees. 33. The above facts weree compiled during the Federal Litigation. Thereafter, more than four hundred clients who fwere illegally solicited contacted the Kassab Law Firm and requested Kassab to represeynt them in litigation against Pohl and his partners. Kassab filed lawsuits on behalf of thCese clients in four different courts in Harris County. Additionally, due to the egregiousness aof Pohl’s violation of the Texas Penal Code and violations of the Texas Disciplinary Rufles of Professional Conduct, Kassab was required to notify the Texas State Bar pursuant Uto Rule 8.03 of the Texas Disciplinary Rules of Professional Conduct. Due to this mandate, Kassab filed grievances against Pohl pursuant to Rule 8.03. some of Pohl’s clients also prepared and filed grievances against Pohl arising out of his egregious conduct. 11 34. Because of these actions in representing clients against Pohl and the grievances filed against Pohl, Pohl filed this retaliatory lawsuit against Kassab alleging conversion and theft of trade secrets. Pohl alleges that Kassab and others stole his property and used it to bring lawsuits and grievances against Pohl. Specifically, Pohl alleges in his petition that, “Kasksab is a lawyer who specializes in suing other lawyers”1 and “Kassab solicited clients/proslpective clients [of Pohl’s] to act as Plaintiffs . . . to bring cases against Pohl for alleged barcra t try and other claims.”2 Thus, Pohl has judicially admitted that he has brought his suit agasinst Kassab simply because Kassab contacted illegally solicited clients to notify them of Pohl’s illegal conduct and to offer to represent them in suits against Pohl. 35. The lawsuit is frivolous and without merit as it is based upon false pretenses and was brought solely for retaliation and harassment purposes. Specifically, Kassab did not steal anything from Pohl. Additionally, Kassab daid not purchase any stolen documents belonging to Pohl. Nor did Kassab purchase anything belonging to Pohl. Moreover, Pohl is not the owner of documents received, if any, from Preecision, Favre, Nicholson, Montague or anyone else. Lastly, none of the documents and/or infofrmation that Kassab may have received from various individuals or entities are Pohl’s trade syecrets as Pohl alleges. Furthermore, Pohl has failed to comply with conditions precedent Cto filing his retaliatory suit for conversion and theft of trade secrets. Specifically, Pohl haas never requested from Kassab, the return of his alleged property. Rather, Pohl abandonedf all of the alleged documents he now accuses Kassab of stealing and/or purchasing. Pohl abanUdoned all of the documents he alleges were stolen and/or purchased because he knew that the documents were not his and that he had no ownership interest in the documents. If Pohl actually believed the subject documents were his, he would have safeguarded the documents rather 1 Pohl Original Petition, p. 6 2 Id. at p. 6-7 12 than abandon them with a convicted felon (Walker) and his cohorts (Seymore and Ladner). Even as of today, the subject documents sit in a warehouse, unattended and not safeguarded. VIII COUNTERCLAIM FOR CIVIL BARRATRY 36. Within the lawsuits that Kassab has filed against Pohl on behalf of his former clients and/or potential clients, Pohl has judicially admitted that a claim for btarratry is not a legal malpractice case. Pohl has also admitted that a because a claim fosr barratry is not a claim for “legal malpractice,” the Discovery Rule does not apply to a barratry claim. Therefore, based upon Pohl’s judicial admissions, the assignment of a barratry claime is permitted under Texas law. 37. Thus, based upon express assignments ouf interest given to Kassab, Kassab brings counterclaims against Pohl and his law firm pursuannt to Texas Civil Practice and Remedies Code, Section 16.069. Section 16.069 provides: r (a) If a counterclaim or cross claim arises out of the same transaction or occurrence that is the basis of an action,o a party to the action may file the counterclaim or cross claim even though as a separate action it would be barred by limitations on the date the party’s ancswer is required. (b) The counterclaim o O r cross claim must be filed not later than the 30th day after the date on whichy the party’s answer is required. Kassab has been assigned barratry claims on behalf of 242 claimants. These counterclaims are timely because athey were filed within 30 days of the date Kassab filed his original answer. f i PRAYER FOR RELIEF Wherefore, Defendants, Counter-Plaintiffs respectfully pray that Plaintiffs recover nothing on their claims and that the Defendants, Counter-Plaintiffs recover on their claims against the Plaintiffs and/or any Third-Party Defendants as follows: 13 i) actual and consequential damages; ii) statutory damages; iii) pre- and post-judgment interest; iv) attorneys’ fees and costs; and v) all other relief to which the Defendants, Counter-Plaintiffs may ber justly entitled. Respectfully submitted, THE KASSAB LAW FIRM / s / Lance sChristopher Kassab LANCE C eHRISTOPHER KASSAB Texasg State Bar No. 00794070 lancer@kassab.law DBAVID ERIC KASSAB Texas State Bar No. 24071351 ydavid@kassab.law i l1214 Elgin Street a Houston, Texas 77004 Telephone: 713.522.7400 f Facsimile: 713.522.7410 ATTORNEYS FOR DEFENDANTS, i COUNTER-PLAINTIFFS LANCE CHRISTOPHER O f KASSAB AND THE KASSAB LAW FIRM C /s/ Murray Fogler l  Murray Fogler State Bar No. 07207300 mfogler@foglerbrar.com f FOGLER, BRAR, O’NEIL AND GRAY, LLP n 909 Fannin, Suite 1640 U Houston, Texas 77010 Telephone: 713-481-1010 Facsimile: 713-574-3224 ATTORNEY FOR THE KASSAB LAW FIRM REGARDING PLAINTIFFS’ AFFIRMATIVE CLAIMS 14 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been forwarded to all parties pursuant to the Texas Rules of Civil Procedure on this the 13th day of May 2022. / s / Lance Christopher Kasesab Lance Christopher KassCabl 15 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. David Kassab Bar No. 24071351 david@kassab.law r Envelope ID: 64509093 Status as of 5/16/2022 7:55 AM CST Case Contacts r i Name BarNumber Email TimestampSubmitted Status Jean C.Frizzell jfrizzell@reynoldsfrizzell.com s5/13/2022 6:22:10 PM SENT Todd Taylor ttaylor@jandflaw.com g5/13/2022 6:22:10 PM SENT Scott M.Favre scott@favrepa.com u 5/13/2022 6:22:10 PM SENT Lance Kassab eserve@kassab.law  5/13/2022 6:22:10 PM SENT Murray JFogler mfogler@foglerbrar.cyom 5/13/2022 6:22:10 PM SENT Murray Fogler mfogler@fbfog.caom 5/13/2022 6:22:10 PM SENT Larry Newsom lnewsom@krcl.com 5/13/2022 6:22:10 PM SENT Andrew Johnson ajohnson@othompsoncoe.com 5/13/2022 6:22:10 PM SENT Andrew J. Sarne asarne@krcl.com 5/13/2022 6:22:10 PM SENT Kathryn Laflin KLafflin@KRCL.com 5/13/2022 6:22:10 PM SENT Zandra EFoley zfoley@thompsoncoe.com 5/13/2022 6:22:10 PM SENT Dale Jefferson 10607900pjefferson@mdjwlaw.com 5/13/2022 6:22:10 PM SENT Raul Herman Suazo 24003C021 suazo@mdjwlaw.com 5/13/2022 6:22:10 PM SENT Kevin Graham Cain 24a01l2371 cain@mdjwlaw.com 5/13/2022 6:22:10 PM SENT Jason M.Ciofalo jason@ciofalolaw.com 5/13/2022 6:22:10 PM SENT Harris Wells o hwells@reynoldsfrizzell.com 5/13/2022 6:22:10 PM SENT Solace SouthwUick ssouthwick@reynoldsfrizzell.com 5/13/2022 6:22:10 PM SENT E. MarieJamison jamison@wrightclosebarger.com 5/13/2022 6:22:10 PM SENT Jessica Z.Barger barger@wrightclosebarger.com 5/13/2022 6:22:10 PM SENT Chris C.Pappas cpappas@krcl.com 5/13/2022 6:22:10 PM SENT Todd Taylor ttaylor@jandflaw.com 5/13/2022 6:22:10 PM SENT David R.Wade lawyerwade@hotmail.com 5/13/2022 6:22:10 PM SENT Katie Budinsky kbudinsky@krcl.com 5/13/2022 6:22:10 PM SENT

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