filings: 40

68 public court filings with full text and structured metadata

Data license: Public court records

This data as json

filing_id date doc_type party description doc_type_detail procedural_posture chain outcome phase filename relief_requested full_text
40 2022-09-19 OBJ Kassab Objection to Pohl’s MSJ evidence Defendants' Objections to Plaintiffs' Summary Judgment Evidence — joint filing by Kassab and Nicholson Defendants challenging admissibility of Pohl's summary judgment evidence including the Pohl Declaration (paragraphs 4, 6, 10-18, 20-32) and numerous exhibits, with additional deposition testimony offered under Rule 107 Evidentiary objections filed September 19, 2022 at 8:16 AM by Kassab and Nicholson defendants jointly, on the morning of the summary judgment hearing. Challenges admissibility of Pohl's September 12, 2022 declaration and exhibits attached to both the traditional and no-evidence MSJ responses. Attaches complete depositions of Ladner, Seymour, and Walker under Rule 107. Addressed to Judge Scot 'Dolli' Dollinger. MSJ-3 N/A Phase 3 2022-09-19_OBJ_Kassab-Objection-to-Pohl-MSJ-Evidence_FILED.pdf Sustain all objections, strike objectionable portions of Pohl Declaration and exhibits, and grant summary judgment for Kassab and Nicholson defendants 9/19/2022 8:16 AM Marilyn Burgess - District Clerk Harris County Envelope No. 68367189 By: Deandra Mosley Filed: 9/19/2022 8:16 AM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIALk DISTRICT DEFENDANTS’ OBJECTIONS TO C PLAINTIFFS’ SUMMARY JUDGMENT EVIDENCE TO THE HONORABLE JUDGE SCOT “DOLLI” DOLLINGEtR: Defendants Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a/ The Kassab Law Firm (“the Kassab Defendeants”) and Tina Nicholson and Baker Nicholson, LLP (“Nicholson”) (both sets ouf Defendants collectively referred to as “Defendants”) file this, their Objections to Plaintiffs’ Summary Judgment Evidence, and would respectfully show athe following. OBJECTIONS TO POHL’S EVIDENCE IN RESPONSE TO TRADITIONAL MSJ Plaintiffs Michael A. Pohel and Law Office of Michael A. Pohl, PLLC (“Pohl”) attached to his summary judfgment responses as Exhibit A a declaration from Pohl dated September 12, 2022 with exhibits (“Pohl Declaration”). Defendants object to the following statements or paragraphs in the Pohl Declaration for the following reasons: i Paoragraph/Statement Objection/Basis ¶ 4 – “During the period that I Conclusory. Unsupported by factual or maintained office space in Mississippi, I legal basis. shared that space only with contractors and employees whom I employed full time and were treated for privilege and confidentiality purposes as functional employees of my law firm. ¶ 6 – “I was informed that Maxwell- Hearsay. Walker had retained Mississippi attorneys to advise it and confirm that its agreement with me as well as the public relations and marketing services it was anticipated to provide under the agreement were in compliance with Mississippi law.” e ¶ 10 – “Precision represented to me that Conclusory. Hearstay. Vague and their independent attorney or attorneys ambiguous as to whio at “Precision” made had reviewed and approved each of the alleged represtentations so this contracts I signed with them. In fact, interested-witneiss testimony is not Precision and/or their independent “clear, positive and direct” as required by attorneys prepared or redrafted several Rule 166a(sc). of the services agreements.” e ¶ 11 – “Precision also represented that, Conclusory. Hearsay. Vague and in addition to their public relations ambiguous as to who at “Precision” made services, they were competent to handle alleged representations so this client liaison services and claims linterested-witness testimony from Pohl management with respect to clients whao is not “clear, positive and direct” as retained me and Jimmy WilliamsonM to required by Rule 166a(c). investigate and potentially prosecute their BP claims.” ¶ 12 – “I am and was the righitful owner Conclusory. Improper lay or expert of all the confidential, pOrivileged and opinion on legal issues for which Pohl is trade secret information and property not properly qualified or designated to that Kassab, Montagupe and Nicholson provide testimony on. Unsupported by obtained from Scott Foavre and Precision factual or legal basis. More specifically, Marketing Group, LLC on which this Pohl’s statements that he is a rightful lawsuit is baseda. l… as a lawyer, I am owner of the information, that the also entitled tco imaintain a copy of the information is a “trade secret,” and that files and havfei a possessory interest in he has a possessory and ownership them. Moroeover, with respect to the interest in the information are attorney-client contracts to which I was conclusory without any supporting basis. a party, as a contracting party I likewise have an ownership interest in each of the attorney-client contracts.” ¶ 13 – “while a single client may have Conclusory. Improper lay or expert the right to request and obtain his/her opinion on legal issues for which Pohl is file, that client does not have the right to not properly qualified or designated to possess or even access other client files. provide testimony on. Unsupported by The compilation of my clients and their factual or legal basis. contact information, or any subset of my clients, belongs to me and is in fact a ‘customer list.’ This is equally true if the materials consist of over 11,000 attorney-client contracts from which one can ascertain my ‘client’ or ‘customer e list’.” C ¶ 14 – “I repeatedly stressed to Precision Conclusory. Heairsay. Vague and and its staff the importance of keeping ambiguous as to wtho at “Precision” made client information confidential including alleged repreisentations so this the attorney-client contracts and the interested-witness testimony from Pohl corresponding files. In turn, Precision is not “clsear, positive and direct” as represented to me that they would be required eby Rule 166a(c). Improper lay providing their marketing and client or expert opinion on legal issues for services exclusively to me and knew and which Pohl is not properly qualified or understood that their work and designated to provide testimony on. communications with clients including Unsupported by factual or legal basis. the underlying information of the clients l and any of my contracts with the clienats were confidential and could not Mbe disclosed without my express consent. Although Precision was a third-party provider of legal related services, for purposes of privileged or cionfidential information, they were eOffectively the functional equivalent of employees working full time for pme out of offices arranged for and poaid for by me. I considered them to be a ‘lawyer representative’ asl that term is used in the Texas Rules iof Civil Evidence. ¶ 15 – “I likoewise took additional steps to Conclusory. Improper lay or expert safeguard my confidential and opinion on legal issues for which Pohl is proprietary information. My offices, not properly qualified or designated to where my information was kept, were at provide testimony on. Unsupported by the top floor of a bank building which factual or legal basis. had 24-hour security. The elevators were programmed such that after hours a person could only access a floor or floor for which that person had authority. The building itself contained numerous security cameras. My firm would lock and secure the offices after office hours, and my files were therefore kept under lock and key. I also made sure my computers were password protected. With respect to my contracts with my clients, the contracts were written in a e way that left no doubt that they were an C agreement between a lawyer and a client t  or clients for the rendition of legal services.” t ¶ 16 – “I did not commit barratry. The Conclusory. Improper lay or expert assertions made by the Defendants in opinion ons legal issues for which Pohl is their motions for summary judgment not propeerly qualified or designated to that I committed barratry and that I provide testimony on. Unsupported by agreed to pay Precision any percentage factual or legal basis. of the attorney’s fees I was to receive is not true.” ¶ 17 – “At all times, I attempted tao Conclusory. Hearsay. Improper lay or conform to the requirements relatinMg to expert opinion on legal issues for which practicing in states in which I was not Pohl is not properly qualified or licensed. I note that the filing process in designated to provide testimony on. the BP Matter permitted the Unsupported by factual or legal basis. participation of non-lawyers. iThere was no requirement of bar Oadmission for filing claims.”  ¶ 18 – “the assertionso that I ever agreed Conclusory. Vague and ambiguous as to to pay any percentage of my attorney's who at “Precision” made alleged fees to Precisiona lare not true. Instead, representations so this interested- the May 25, c2i012 and July 15, 2012 witness testimony from Pohl is not Contracts faiccurately reflect the “clear, positive and direct” as required by agreement oorally discussed and Rule 166a(c). Unsupported by factual or understood by all of the parties before legal basis. their execution. The agreement required that the Precision "shall keep accurate daily time records of all efforts expended on behalf of LOMAP." The %-of- attorney's-fees clause was simply to impose a "cap" on amounts that may be due under the other terms of the agreement, not an independent promise to pay any percentage of the attorney's fees earned by LOMAP on the subject claims. This was orally discussed and understood by the parties before the May 25, 2012 and July 15, 2012 Contracts were executed.” ¶ 20 – “Further with respect to the terms Conclusory. Vague andC ambiguous as to of agreement and services to be provided who at “Precisiont ” made alleged under the May 25, 2012 Contract and representations sio this interested- the July 15, 2012 Contract, I was witness testimonty from Pohl is not informed by Precision that they wanted “clear, positive aind direct” as required by to confer with their attorneys before Rule 166a(c). Unsupported by factual or finalizing and executing the agreement legal basiss. documentation. We specifically discussed e that the inclusion of the agreed maximum-price provisions was essential to me in agreeing to either a "reasonable rate" formula or a specified contract rate. Precision subsequently confirmed l to me that they had conferred with theiar Mississippi attorneys, who had advMised that the terms of the agreement and anticipated services thereunder were lawful, and executed the agreement accordingly.” i ¶ 21 – “Precision and its members Hearsay. agreed they would orpganize and host festivals, town hall moeetings and other gatherings to appropriately educate the public as part of thleir marketing efforts.” ¶ 22- “On my cbiehalf, Precision and its Conclusory. Vague and ambiguous as to members agrfeied they would organize who at “Precision” Pohl is referring to, so and host foestivals, town hall meetings this interested-witness testimony from and other gatherings to appropriately Pohl is not “clear, positive and direct” as educate the public as part of their required by Rule 166a(c). Unsupported marketing efforts. Precision was also by factual or legal basis. responsible for training and supervising their staff to ensure optimal results and compliance with the rules governing their marketing activities.” ¶ 22 – “This included Precision sending Conclusory. Vague and ambiguous as to me falsified and inflated invoices and who at “Precision” Pohl is referring to, so expense information. It was also later this interested-witness testimony from discovered that Precision had Pohl is not “clear, positive and direct” as systematically overcharged me on all required by Rule 166a(c). Unsupported amounts I paid them under the public by factual or legal basis. relations agreement.” ¶ 23 – “Precision admitted that they had Conclusory. Vague andC ambiguous as to been stealing from me. Thus, from the who at “Precision” otr “PR Consultants” inception of my relationship with PR Pohl is referring tio, so this interested- Consultants, they consistently witness testimonty from Pohl is not overstated to me the amount of the “clear, positive aind direct” as required by actual costs they charged me for, and Rule 166a(c). Unsupported by factual or then misappropriated, converted and/or legal basiss. stole the inflated amounts for their own e use and benefit.” ¶ 24 – “Precision took my property Conclusory. Vague and ambiguous as to including my engagement agreements, who at “Precision” Pohl is referring to, so client files, contact information, lthis interested-witness testimony from computers and other informatioan Pohl is not “clear, positive and direct” as without my permission. These files wMere required by Rule 166a(c). Unsupported at one time maintained in approximately by factual or legal basis. Hearsay as to seventeen clear plastic file containers. what Ladner – who is not a party to this Ladner admitted absconding with those case – stated. files from my satellite law ioffice and, without my consent, keptO them at his residence until they were later delivered, also without my consenpt, to Scott Favre, who had purchasedo Precision (from Walker, Seymour, and Ladner) and became its managilng member.” ¶ 24 – “Precf iision and Tina Nicholson Conclusory. Vague and ambiguous as to refused to roeturn and converted to their who at “Precision” Pohl is referring to, so own use my computers that I purchased this interested-witness testimony from for my office and which Precision used Pohl is not “clear, positive and direct” as while there performing services for me. required by Rule 166a(c). Improper lay Those computers held software and or expert opinion on legal issues for stored data that I had paid for, which Pohl is not properly qualified or specialized legal forms (that had been designated to provide testimony on. prepared in compliance with various Unsupported by factual or legal basis. state law after consultation with local counsel in those jurisdictions), marketing information and other trade secrets, my proprietary administrative client forms, various fee-agreement forms prepared in accordance with the laws of various states, internal emails and other work product relating to the BP claims and other matters for which e Precision rendered services in connection C with our services agreements.” t  ¶ 25 – “This theft and unlawful Conclusory. Heatrsay. Vague and disclosure was made even more ambiguous as toi who at “Precision” Pohl egregious by the fact that, from the is referring to, so this interested-witness outset of their contractual relationship testimony sfrom Pohl is not “clear, with me, Precision expressed their positive aend direct” as required by Rule understanding of the confidential nature 166a(c). Pohl’s statement about what of the information based on their prior “appears” to have occurred is not experience in providing litigation related competent summary judgment evidence, services to attorneys, a field in which and his statement about a “barratry Precision held themselves out to me as lscheme” is conclusory and unsupported experienced professionals. Neverthelesas, by factual or legal basis. Moreover, not without my consent, and without lMegal designated to opine on the issue of legal title to the contracts, documents, title. computers, passwords or data stored thereon, Precision sold the contracts, documents, computer, passwoirds and/or stored data to Scott FavreO (even after I had informed Favre that the materials had been stolen from pme by Precision), who it appears eventoually sold some or all of those items and the information therein to Kaslsab, Montague and Nicholson for theiir barratry scheme. ¶ 26 – “Aso part of that enforcement of Conclusory and unsupported by factual the settlement agreement, certain or legal basis. Defendants were sanctioned.” ¶ 27 – “The materials at issue have Conclusory. Improper lay or expert independent economic value from not opinion on legal issues for which Pohl is being generally known to or not properly qualified or designated to ascertainable through proper means by provide testimony on. Unsupported by another person who can obtain economic factual or legal basis. value from them.” ¶ 27 – “I agree with this valuation and Conclusory. Improper lay or expert believe it constitutes the fair market opinion on legal issues for which Pohl is price for what an investor would pay for not properly qualified or designated to such information. However, the provide testimony on. Pohl’s statement conversion and misappropriation of my about what he “believes” is not client information has deprived me of competent summary judgement evidence. this value.” Unsupported by factuaCl or legal basis. ¶ 28 – “I have suffered injury as a result Conclusory. Impropter lay or expert of the Defendants’ misappropriation of opinion on legal issiues for which Pohl is my trade secrets and conversion of my not properly quatlified or designated to property. My injury includes the costs I provide testimDoiny on. Unsupported by have incurred in legal fees and expenses factual or legal basis. Pohl fails to that I would never have incurred but for provide susfficient factual support about the conversion of my property and the fees hee alleges as damages. misappropriation of my trade secrets. I have personally incurred hundreds of thousands of dollars in attorneys’ fees and expenses in relation to defending the lawsuits orchestrated by Defendants, l including the Berry, Brumfielad, Cheatham, and Gandy lawsuits. I Mwas also harmed, as I paid a substantial sum of money as part of a settlement agreement under which certain Defendants were required to ireturn my materials and not fomOent litigation against me. But I did not receive those benefits.” p ¶ 29 – “The filing process in the BP Conclusory. Hearsay. Improper lay or Matter permitteadl the participation of expert opinion on legal issues for which non-lawyers. Tchiere was no requirement Pohl is not properly qualified or of bar admissfioin for filing claims.” designated to provide testimony on. o Unsupported by factual or legal basis. ¶ 30 – “At no time did I knowingly Conclusory. Unsupported by factual or participate in any illegal solicitation of legal basis. clients in Mississippi, Louisiana, Texas or elsewhere. I always instructed everyone in my employ to abide by the laws of the state in which they were acting. I, at all times, attempted to adhere to the rules of the State Bar of Texas and other relevant states regarding the solicitation of clients. ¶ 31 – “Prior to the two year period Conclusory. Vague and ambiguous as to leading up to the filing of this case, I was who at “Precision” Pohl is referring to, so unaware that Scott Favre and Precision, this interested-witness testimony from with the assistance of Tina Nicholson, Pohl is not “clear, positivee and direct” as had sold my information to Kassab and required by Rule 166Ca(c). Unsupported Montague. And, in fact, that sale by factual or legal bast is. occurred in November of 2016, less than i two years before this suit was filed. t ¶ 32 – “The grievances involved those Conclusory.  same allegations.” s Defendants request the Court to sustain these objections and strike these objectionable portions of the Pohl Declaration. With those statements struck, Pohl has no evidence to support his claimls against Kassab, rendering summary judgment appropriate. M In addition, Defendants object to several of Pohl’s summary judgment exhibits on the following grounds. Exhibit/Description Objection/Basis Exhibit F - November 15, 2019 letter Hearsay. Irrelevant because outcomes of from Office of Cohief Disciplinary grievance proceedings are not res Counsel. judicata in civil matters. See Charles v. l Diggs, No. 14-19-00725-CV, 2020 Tex. Exhibit G – Feibruary 24, 2020 letter App. LEXIS 8502, at *5 (Tex. App.— from Office iof Chief Disciplinary Houston [14th Dist.] Oct. 29, 2020, pet. Counsel. o denied) (client’s claim against lawyer Exhibit H – May 14, 2020 Letter from was not precluded by dismissal of Board of Disciplinary Appeals. grievance because “the disciplinary rules do not set the standard for civil Exhibit I – January 14, 2020 letter from liability”); TEX. RULES DISCIPLINARY P. R. Office of Chief Disciplinary Counsel. 17.03 (“Neither the Complainant nor the Respondent is affected by the doctrines Exhibit J – April 10, 2020 Letter from of res judicata or estoppel by judgment Board of Disciplinary Appeals. from any Disciplinary Action.”). Exhibit K – January 9, 2020 letter from Office of Chief Disciplinary Counsel. Exhibit L – April 10, 2020 Letter from Board of Disciplinary Appeals. Exhibit M – January 9, 2020 letter from e Office of Chief Disciplinary Counsel. C Exhibit N – April 10, 2020 Letter from Board of Disciplinary Appeals. t Exhibit O – January 9, 2020 letter from  Office of Chief Disciplinary Counsel. Exhibit P – April 10, 2020 Letter from Board of Disciplinary Appeals. Exhibit T – January 9, 2020 letter from Office of Chief Disciplinary Counsel. l Exhibit R – October 3, 2017 Letter fMrom Hearsay. Magdalena Santana  Exhibit S – Transcription of audiotaped Hearsay as to statements made by conversation between Lance Kiassab and Magdalena Santana. Magdalena Santana. O Exhibit Y – emails and letter from Hearsay counsel p Additionalalyl, Pohl attached to his response only portions of the depositions of Scott Walker f(iExhibit D), Kirk Ladner (Exhibit V), and Steve Seymour (Exhibit W), taken August 29-31, 2022, after Defendants filed their motions for summary judgment. For purposes of optional completeness, Defendants attach the entire depositions of these witnesses as Exhibits 1 (Ladner), 2 (Seymour) and 3 (Walker) to this pleading and asks the Court to consider those depositions part of the summary 10 judgment record. See TEX. R. EVID. 107 (“If a party introduces part of an act, declaration, conversation, writing, or recorded statement, an adverse party may … introduce any other act, declaration, conversation, writing, or recorded statement that is necessary to explain or allow the trier of fact to fully understkand the part offered by the opponent.”). This exhibits include, for example, adCditional proof for Defendants’ summary-judgment arguments, such as Kirk Ladner’s following testimony: i • Precision owned the marketing and client lists. Ex. 1 at 44-45. • Helping hands decided which law firms to refer clients to. Ex. 1 at 55-56, 62- 64 • Ladner did his own research to find lthe motor vehicle accident cases. Ex. 1 at 97, 285-89. M • Pohl was really splitting attorney’s fees with Precision and his contracts were a deceptive smokescreein to make the scheme appear legal. Ex. 1 at 77-79, 83-85, 94-95, 269-271, 276, 287-288, 398-416, 443 • Forms and maroketing lists used by Precision belonged to Precision. Ex. 1 at 128-29. l • Pohl nef iver told Lander to return the documents, which belonged to ladner. Ex. 1 at 133, 173-74 • The BP claimants were clients of Precision first. Ex. 1 at 214-215. • Pohl never told Ladner to keep the information confidential. Ex. 1 at 232-35, 264-65, 500-502 11 • Spreadsheets of claimants and pre-questionnaire forms belonged to Precision. Ex. 1 at 244-245, 262-263. • Pohl committed barratry. Ex. 1 at 274-280, 285-86 • Helping Hands and GM Verification signed up the claimants as their own clients. 444 C Additionally, Steve Seymour testified that Walker creaited claimant lists but Pohl never said the client lists were confidential. Ex. 2 ati 96-98, 147-149, 221-222. Walker testified that the marketing lists were Precission’s work product and so was the initial screening forming Precision had claimants compete. Ex. 3 at 232-33, 237-242. OBJECTIONS TO POHL’S EVIDENCE INl RESPONSE TO NO-EVIDENCE MSJ Because the Pohl DefendantsM use the same declaration to support their Response to the No-Evidence Motion for Summary Judgment, Defendants incorporate by reference all thie above-stated objections and assert them as to Pohl’s declaration attached to the No-Evidence Response as Exhibit A. EXHIBIT/DES o CRIPTION EXHIBIT/BASIS Exhibit BB – Omnibus Transcript Hearsay Exhibit D – Grcieivance documents Hearsay. Irrelevant because outcomes of f i grievance proceedings are not res o judicata in civil matters. See Charles v. Diggs, No. 14-19-00725-CV, 2020 Tex. App. LEXIS 8502, at *5 (Tex. App.— Houston [14th Dist.] Oct. 29, 2020, pet. denied) (client’s claim against lawyer was not precluded by dismissal of grievance because “the disciplinary rules do not set the standard for civil liability”); TEX. RULES DISCIPLINARY P. R. 12 17.03 (“Neither the Complainant nor the Respondent is affected by the doctrines of res judicata or estoppel by judgment from any Disciplinary Action.”). Exhibit S – Zavitsanos Report Hearsay, unsworn. Exhibit T – Pohl Deposition at 115-116 Hearsay regarding what third-parties allegedly told Nicholson. Also, Pohl’s testimony was nonresponsive. Exhibit Y – Pohl Declaration ¶ 4 Conclusory. Improiper lay or expert opinion on legal sitssues for which Pohl is not properly Dquialified or designated to provide testimony on. Unsupported by factual or slegal basis. More specifically, Pohl’s statements that he is a rightful owner of the information, that the information is a “trade secret,” and that he has a possessory and ownership interest in the information are lconclusory without any supporting basis. ¶¶ 5, 6 Conclusory. Vague and ambiguous as to  who at “Precision” Pohl is referring to, so this interested-witness testimony from Pohl is not “clear, positive and direct” as i required by Rule 166a(c). Unsupported O by factual or legal basis. Hearsay as to  what Ladner – who is not a party to this p case – stated. ¶ 7 Conclusory. Hearsay. Vague and a l ambiguous as to who at “Precision” Pohl c i is referring to, so this interested-witness f i testimony from Pohl is not “clear, o positive and direct” as required by Rule 166a(c). Pohl’s statement about what “appears” to have occurred is not competent summary judgment evidence, and his statement about a barratry scheme is conclusory and unsupported by factual or legal basis. Moreover, not designated to opine on issue of legal ¶ 8 title. 13 ¶ 9 Conclusory. Vague and ambiguous as to who at “Precision” Pohl is referring to, so this interested-witness testimony from Pohl is not “clear, positive and direct” as required by Rule 166a(c). Unsupported by factual or legal basis. e ¶¶ 10, 13, 14 Not designated as an expert on damages, and his damages topines are conclusory, speculative, unireliable, and lack any factual support. ¶ 11 Conclusoery CONCLUSION & PRAYER For the foregoing reasons, the Court should sustain these objections to Pohl’s summary judgment evidence. With the aobjections sustained, the Court should grant Kassab’s request for traditional and no-evidence summary judgment and order that Pohl take nothing his claims against Kassab. O Respectfully submitted, p THE KASSAB LAW FIRM /s/ David Eric Kassab l DAVID ERIC KASSAB i Texas State Bar No. 24071351 i david@kassab.law o LANCE CHRISTOPHER KASSAB Texas State Bar No. 00794070 lance@kassab.law NICHOLAS R. PIERCE Texas State Bar No. 24098263 nicholas@kassab.law 1214 Elgin Street Houston, Texas 77004 Telephone: 713-522-7400 14 Facsimile: 713-522-7410 E-Service: eserve@kassab.law ATTORNEYS FOR KASSAB DEFENDANTS THOMPSON, COE, COUSINS & IRONS, LLP By: /s/ Andrew L. Johneson Andrew L. Johnson C State Bar No.: 24060025 Zandra E. Foley State Bar No.: 2t4032085 Benjamin S. Riitz State Bar No.: 24096147 One Riverway, Suite 1400 Houstoen, Texas 77056 (713) 403-8210 – Telephone (71u3) 403-8299 – Facsimile ajohnson@thompsoncoe.com zfoley@thompsoncoe.com lbritz@thompsoncoe.com ATTORNEYS FOR DEFENDANTS TINA NICHOLSON AND BAKER fNICHOLSON, LLP OCERTIFICATE OF SERVICE I certify that onp this date, September 19, 2022, I electronically filed this document with the Clerk of the Court using the eFile.TXCourts.gov electronic filing system which will send notification of such filing to all parties or counsel of record. f /s/ David Eric Kassab DAVID ERIC KASSAB 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 e Bar No. 24071351 C david@kassab.law t Envelope ID: 68367189 r Status as of 9/19/2022 8:41 AM CST Case Contacts Name BarNumber Email sTimestampSubmitted Status Solace Southwick ssouthwick@reynoldsfrizzell.com 9/19/2022 8:16:53 AM SENT Zandra EFoley zfoley@thompsoncoe.com r 9/19/2022 8:16:53 AM SENT Andrew Johnson ajohnson@thompsoncoe.com 9/19/2022 8:16:53 AM SENT Andrew J. Sarne asarne@krcl.com 9/19/2022 8:16:53 AM SENT Benjamin Ritz britz@thompsoncoe.conm 9/19/2022 8:16:53 AM SENT Kathryn Laflin KLaflin@KRCL.com 9/19/2022 8:16:53 AM SENT Dale Jefferson 10607900 jefferson@mdjwlarw.com 9/19/2022 8:16:53 AM SENT Raul Herman Suazo 24003021 suazo@mdjwlaw.com 9/19/2022 8:16:53 AM SENT Kevin Graham Cain 24012371 cain@mdjwlaw.com 9/19/2022 8:16:53 AM SENT Larry Newsom lnewsom@fkrcl.com 9/19/2022 8:16:53 AM SENT Jason M.Ciofalo jason@ciofalolaw.com 9/19/2022 8:16:53 AM SENT Chris C.Pappas cpappas@krcl.com 9/19/2022 8:16:53 AM SENT Todd Taylor titaylor@jandflaw.com 9/19/2022 8:16:53 AM SENT Misty Davis fmdavis@reynoldsfrizzell.com 9/19/2022 8:16:53 AM SENT Non-Party Witness Billy Shepherd bshepherd@spcounsel.com 9/19/2022 8:16:53 AM SENT Deidre Hicks y GWS_GROUP@spcounsel.com 9/19/2022 8:16:53 AM SENT Harris Wells hwells@reynoldsfrizzell.com 9/19/2022 8:16:53 AM SENT Jean C.Frizzell C jfrizzell@reynoldsfrizzell.com 9/19/2022 8:16:53 AM SENT Todd Taylor  ttaylor@jandflaw.com 9/19/2022 8:16:53 AM SENT Lawyer Wade a lawyerwade@hotmail.com 9/19/2022 8:16:53 AM SENT Scott M.Favre c scott@favrepa.com 9/19/2022 8:16:53 AM SENT Andrea Mendez f i andrea@kassab.law 9/19/2022 8:16:53 AM SENT Lance Kassab o lance@kassab.law 9/19/2022 8:16:53 AM SENT David Kassab david@kassab.law 9/19/2022 8:16:53 AM SENT Nicholas Pierce nicholas@kassab.law 9/19/2022 8:16:53 AM SENT Murray Fogler mfogler@fbfog.com 9/19/2022 8:16:53 AM SENT Murray J. Fogler 7207300 mfogler@foglerbrar.com 9/19/2022 8:16:53 AM SENT Katie Budinsky kbudinsky@krcl.com 9/19/2022 8:16:53 AM ERROR E. MarieJamison jamison@wrightclosebarger.com 9/19/2022 8:16:53 AM SENT Jessica Z.Barger barger@wrightclosebarger.com 9/19/2022 8:16:53 AM SENT

Links from other tables