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44 2022-11-15 MTN Kassab 1st Supp. Motion to Designate RTP Kassab Defendants' Supplemental Motion to Designate Responsible Third Parties (Shepherd, Walker, Seymour, Ladner, Dona Pohl, Jaimes, Talley, Santana) Filed November 15, 2022 before Judge Scot Dollinger, 189th Judicial District, Harris County, Texas. Kassab's original RTP motion was filed May 13, 2022 (more than 60 days before the October 10, 2022 trial setting). Pohl objected May 30, 2022. Court denied the original motion on October 31, 2022 but gave Kassab an opportunity to replead. Trial reset to December 5, 2022. RTP-1 N/A Phase 3 2022-11-15_MTN_Kassab-Supp-Mtn-to-Designate-RTP_FILED.pdf Grant the Kassab Defendants' Amended Motion to Designate Responsible Third Parties (George W. (Billy) Shepherd, Scott Walker, Steve Seymour, Kirk Ladner, Dona Pohl, Edgar Jaimes, Ken Talley, Magdalena Santana) and grant all other relief in law or equity 11/15/2022 1:31 PM Marilyn Burgess - District Clerk Harris County Envelope No. 70189306 By: Deandra Mosley Filed: 11/15/2022 1:31 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS SCOTT FAVRE, et al § 189th JUDICIAkL DISTRICT DEFENDANTS, LANCE CHRISTOPHER KASSAB AND LAlNCE CHRISTOPHER KASSAB, P.C. D/B/A THE KASSAB LAW FIRM’S SUPPLEMENTAL MOTION TO DESIGNATE RESPONSIBLEc THIRD PARTIES TO THE HONORABLE JUDGE SCOT DOLLINGER: s Defendants, Lance Christopher Kassab and Lance Christopher Kassab, P.C. D/B/A The Kassab Law Firm (“Kassab”), and file this, their Amended Motion to Designate Responsible Third Parties. REQUESTElD RELIEF 1. Kassab seeks to designate GMeorge W. (Billy) Shepherd (Shepherd), Scott Walker (Walker), Steve Seymour (Seymour) oand Kirk Ladner (Ladner), Dona Pohl (Dona), Edgar Jaimes (Jaimes), Ken Talley (Talley), Magdalena Santana (Santana) as responsible third parties in this litigation. Shepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley and Santana are all persons who are alleged to have caused or contributed to causing in any way the harm for which recovery of damages by Pohl is sought. Thus, they are all responsible third parties in this cause. TEX. CIV. PRAC. &c REM. CODE § 33.011(6). U FACTS 2. Pohl is a lawyer who commits barratry and has prayed on the less fortunate to earn a living. On October 18, 2014, three Mississippi residents, Scott Walker (“Walker”), Kirk Ladner (“Ladner”) and Steve Seymour (“Seymour”), and their related entities, including Precision Marketing Group, LLC (“Precision”), filed suit against Michael Pohl (“Pohl”) and others in Mississippi federal court (the “Mississippi Litigation”). There, Precision, Walker, Ladner and Seymour alleged that: (1) they had a joint venture with Pohl to sign up clients with economic loss claims stemming from the BP Deepwater Horizon oil spill and clients with personal injury claims; (2) that they successfully obtained these clients for Pohkl; and (3) that Pohl breached their agreement by not paying them what was owed, includingl their agreed share of Pohl’s attorney’s fees. c 3. The evidence presented in the Mississippi Litigastion established that Pohl engaged in barratry. See TEX. PEN. CODE § 38.12 (defining b arratry generally as the improper solicitation of clients). During that litigation, Walker testified that Pohl retained him and Precision to “provide marking services to auto accident victims[.]” 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 himsealf and his company “a pass-through for barratry money.” All told, Walker, Ladner and Precision received over $5 million in “barratry pass- through money” from Pohl and otheer lawyers to solicit potential clients, both auto-accident victims and those involved in tfhe BP litigation. They would use this money to pay contract workers to solicit clients. Thyey would locate and instruct contract workers on how to accomplish the solicitation. They tCrained “40 or 50 people” on how to “go out and solicit contracts.” 4. Walkaer and his team at Precision were first retained by Pohl to “recruit clients” with losses resuflting from the Deepwater Horizon oil spill. When that litigation dwindled, Pohl shifted hiUs focus to auto accident cases, knowing that the group at Precision could go out and get him those types of clients. To accomplish this task, individuals at Precision would receive “Google alerts” or leads from Pohl on recent catastrophic auto accidents. Walker testified that he, Ladner, or someone working for them would go to the victims of the auto accident to “do marketing” by letting them know “there were attorneys [who] could help.” In exchange, these runners – whoever visited the victims – where paid between $2,500 and $5,000 to solicit the client. These payments flowed from Pohl through his wife’s wholly owned company, “Helping Hands Financing,” to Precision, to each individual runner. Walker would simply submit to Pohl the amount that Precision paid its runners and Pohl would reimburse Precision. k 5. One of the runners, Santana, testified to the barratry in her Sleptember 24, 2016 affidavit filed in the Mississippi Litigation. She testified that Pohl scent her on “dozens and dozens of car wreck cases all over the country.” Pohl would emasil Santana the link of news coverage depicting the accident and ask her “to go to the victim or the victim’s family and try to get them to sign up with him.” Pohl offered to pay Santana “$5,000 per case that [she] signed, plus a percentage of his attorney’s fees.” Santana was 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 thea emergency room, their hospital rooms or at the funerals.” Id. Pohl told Santana that minorities “were especially vulnerable since they tended not to know that the law prohibited barraetry.” According to Pohl, they “were easier to sign up.” 6. Pohl would pay Safntana “money to give to the victims or their families” but “only if they agreed to sign a Pohly representation contract.” Pohl advised Santana that the money was a “foot in the door” but Cinstructed Santana not to mention that she was there on behalf of a lawyer “until after they agraeed to take the money.” “If the client agreed to hire Pohl, then [Santana] was to have the cliefnt sign a ‘Helping Hands’ contract.” Pohl would then give Santana the money to pay the cUlient “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.” 7. Santana further confirmed the barratry in her deposition taken in the Mississippi Litigation. She testified that she was hired by Pohl to solicit auto accident cases, the first one was an accident where a woman and her unborn child lost their lives. Santana was instructed by Walker, who was instructed by Pohl, to personally 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. Santana visited the funeral of the deceased and got the family to feel comfortable with her. Althokugh the mother was grieving, Pohl told Santana: “take no prisoners, this is a cut-throat businelss, you get in there and you do whatever it takes to get this client.” The solicitation was succcessful after Pohl gave Santana $2,000 to “give to the client to convince her into signing ovesr with the firm.” 8. Pohl later requested Santana to sign an agreement promising not to go to any law enforcement, including various State Disciplinary boards regarding any wrongdoing, criminal or unethical conduct. In fact, it is undisputed that Pohl paid Santana $50,000 in cash to sign this agreement, which was delivered to her in Florida by Pohl’s paralegal, Jaimes. Santana confirmed this in an affidavit and Jaimes confirmed thisa in his deposition. Santana signed the statement and received the cash, although she believed she was “forced to sign” it while “under duress”. 9. Another runner, Talleey, also testified in the Mississippi Litigation about the barratry. Talley solicited over 20f auto accident cases for Pohl, including two families who hired Kassab to sue Pohl for barraytry. Talley testified that he was first hired in relation to BP claims to find “folks that lost moCney due to the oil spill” and “sign them up” and “get a fee for it.” Talley solicited and signeda up more than 800 BP claims for Pohl and was paid between $75 and $350 per client. f 10U. Talley eventually transitioned to soliciting auto accident victims, “calling on folks that had bad accidents.” Talley recalls that the first client he solicited was in “the hospital in intensive care.” Talley maintained $1,000 in cash to pay the accident victims to “help them with problems” and influence them to hire a lawyer, because the victims received the money only if they “were signed up.” Talley would advise the victims that he had attorneys who could help them, and that one of those attorneys was Pohl. For each auto accident case he solicited, Talley was paid a fee of $1,400 plus his expenses by Pohl, through Walker and Precision. On some cases, Talley was to receive a portion of Pohl’s attorney’s fees, and even discussed with Pohl the “percentage of settlements” he was to receive. When asked whether Pohl knewk he was getting paid to “contact vehicle accident victims,” Talley responded, “the money lwas coming from Edgar [Jaimes] who worked for him.” 1CR301. Although his paycheck wcas from Precision, “the funding came by way of Edgar [Jaimes].” Talley testified that both she and Pohl knew what they were doing was illegal.  11. In May of 2016, during the Mississippi Litigation, an insurance adjuster named Scott Favre (“Favre”) purchased Precision and all the company’s assets, including client lists, marketing lists, documents, files, computers, etc. from Walker, Seymore and Ladner. Included in the purchase was the Mississippi Litigaation, thus, Precision’s claims against Pohl in the Mississippi Litigation were assigned to Favre. Favre and Precision were represented in the Mississippi Litigation by Texas laweyer, Tina Nicholson and her firm, Baker Nicholson, LLP (“Nicholson”). Pohl asserted coufnter claims in the Mississippi Litigation alleging that Walker and Precision (and other uynknown defendants) converted his property. Pohl then moved to dismiss the claims agaCinst him, arguing, among other things, that the agreements between him and the runners weare illegal and unenforceable. More specifically, Pohl argued that under both Texas and Missfissippi law “it is illegal for a non-lawyer to accept or agree to accept money to improperUly solicit clients for a lawyer.” The Mississippi federal court rejected Pohl’s contention, stating that the agreements to solicit clients would only be a violation of Texas law and Texas disciplinary rules, which did not apply to Precision, a Mississippi company, and Walker and Ladner, Mississippi residents. Having failed to obtain summary dismissal, Pohl settled the Mississippi Litigation with all parties, including Favre, hoping to forever conceal his barratry operation. Although Pohl had already paid the runners approximately $5,000,000 in barratry money, Pohl paid the runners an additional $1,000,000 to settle the Mississippi Litigation. 12. Kassab heard about the allegations being made by the runners in the Mississippi Litigation. Kassab searched PACER, the federal court’s online system, obtaininkg a plethora of information related to the Mississippi Litigation. Kassab met with Favrle and Precision’s counsel, Nicholson. Kassab obtained information directly from them, icncluding the names and addresses of Pohl’s former clients or prospective clients from Precsision’s marketing and client lists. Precision, through Favre, informed Kassab that it owned all of its marketing lists and information and also informed and verified that Precision was the main Plaintiff suing Pohl in the Mississippi Litigation. Thereafter, Kassab used Precision’s marketing and client lists to notify individuals who he believed may have been victims of Pohl’s barratry. Hundreds of individuals responded, indicating that they haad been personally solicited to hire Pohl in their auto accident or BP claims. Kassab agreed to represent these clients, and more than 400 individuals hired Kassab to represent them agaienst Pohl and other lawyers involved in the illegal barratry scheme. f 13. Kassab filed yfour petitions on behalf of these barratry victims in Harris County, Texas (the “barratry laCwsuits”). The barratry lawsuits communicated matters of public concern: that Pohl conspiread to commit barratry. After reviewing the evidence obtained from the Mississippi Litifgation, Kassab believed he had a duty to file a grievance against Pohl pursuant to Rule 8.03U of the Texas Disciplinary Rules of Professional Conduct,1 and he did. Kassab also filed a grievance against Pohl on behalf of one of his clients. In the grievances, Kassab and his 1 See TEX. DISC. R. PROF’L COND. 8.03(a) (except in circumstances which do not apply here, “a lawyer having knowledge that another lawyer has committed a violation of applicable rules of professional conduct that raises a substantial question as to that lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects, shall inform the appropriate disciplinary authority.”). client expressed matters of public concern relating to Pohl’s legal services in the marketplace and petitioned the State Bar of Texas to reprimand and discipline Pohl in order to protect the public as is mandated by Rule 8.03. 14. Unfortunately, in direct retaliation to the lawsuits and grievanceks filed against Pohl, Pohl filed this retaliatory litigation against Kassab, Precision, Nichlolson, Favre and Montague, alleging breach of contract, theft of trade secrets, conversiocn and civil conspiracy. Specifically, Pohl alleged that these parties were “acting in cosmbination with the agreed objective” to misappropriate his trade secrets and convert the marketing lists and attorney-client contracts that Pohl hired Precision to obtain. Pohl alleges Favre and Precision, with Nicholson’s assistance, converted this property and provided it to Kassab and Montague in order to solicit Pohl’s former clients “to bring cases against Pohl for alleged barratry and other claims.” aIII AMRGUMENT 15. “A defendant may seek too designate a person as a responsible third party by filing a motion for leave to designate that person as a responsible third party. The motion must be filed on or before the 60th day before the trial date unless the court finds good cause to allow the motion to be filed at a later date.” TEX. CIV. PRAC. & REM. CODE § 33.004(a). That occurred here, with Kassab filing his motion on May 13, 2022, more than 60 days before the October 10, 2022 trial settingc. The current trial setting is December 5, 2022. Thus, the statute required the Court to “grant leave to designate the named person as a responsible third party unless another party files an objection to the motion for leave on or before the 15th day after the date the motion is served.” Id. at § 33.004(f). 16. Pohl filed his objection on May 30, 2022. Still, the Court was required to “grant leave to designate the person as a responsible third party unless the objecting party establishes … the defendant did not plead sufficient facts concerning the alleged responsibility of the person to satisfy the pleading requirement of the Texas Rules of Civil Procedure[.]” Id. at § 33.004(f). In any event, the Court denied the Kassab Defendants’ Motion to Designate Responsible Third Parties on October 31, 2022, but gave the Kassab Defendants an opportunity to rekplead. 17. A responsible third party is “any person who is alleged tlo have caused or contributed to causing in any way the harm for which recovery of damagces is sought, whether by negligent act or omission, by any defective or unreasonably dangerosus product, by other conduct or activity that violates an applicable legal standard, or by any combination of these.” Id. at § 33.011(6). Pohl claims that his harm is the allegedly “unlawful taking” or “use” of Pohl’s purported trade secret information.2 Kassab denies Pohl’s allegations. But even assuming they are true, Kassab’s designation satisfies the minimal notice pleading standard to demonstrate that the Designated Parties caused or contributeda to causing “in any way” the loss of or eventual alleged misuse of purported trade secret information. See In re CVR Energy, Inc., 500 S.W.3d 67, 80 (Tex. App.—Houston [1st eDist.] 2016, no pet.) (“The standard for designating a potentially responsible third partyf is notice pleading under the Texas Rules of Civil Procedure.”). 18. Kassab allegeys that Walker, Ladner and Seymour are responsible for the harm alleged to the extent thCey misappropriated Pohl’s trade secrets in the first instance and sold them to Scott Favre, whoa Pohl alleges then sold them to Kassab to pursue the barratry litigation. In fact, Pohl himsfelf, swore under oath that Walker, Lander and Seymour, who Pohl identified collectiveUly as the “PR Consultants,” attempted to sell his “accumulated work product to third parties”3 and “undertook to convert, misappropriate for themselves and/or market to third parties 2 Pohl RTP Objection, at 2. 3 Exhibit 1, Pohl June 19, 2018 Affidavit, at ¶ 18. claimant files and other information and materials that belong to me.”4 Pohl testified that the purported information stolen by Walker, Ladner and Seymour is the same information that Pohl claims is his trade secrets here: “original client contingency fee contracts between [Pohl’s] clients and [Pohl], documentation of contact and personal information, claim iknformation and supporting materials.”5 Pohl testified that this purportedly trade secret informaltion was delivered or sold Walker, Ladner and Seymour “without his consent” to Favre.6 Poch t l alleges in this lawsuit that Favre then sold that same information to Kassab to pursue barrsatry claims against Pohl.7 If any loss or eventual misuse of Pohl’s purported trade secret information did occur, Walker, Ladner and Seymour clearly caused or contributed to causing it, as had Walker, Ladner and Seymour not stolen Pohl’s alleged trade secrets as he alleges, they could not have sold the alleged trade secrets to Favre and thus, Favre could not have given the alleged trade secrets to Kassab. a 19. Walker testified under oath that he, Seymour and Ladner, through Precision, owned all the assets/property, includieng computers and documents that were transferred to Favre. Walker also testified that he hafd the legal right and authority, through Precision, to sell and transfer all the subject assyets/property to Favre. Moreover, Walker, Seymour and Ladner certified that they ownCed all of the subject property/assets and had authority to transfer all of the subject property/assaets to Favre. If Walker, Seymour and Ladner did not have the legal right to transfer all of thfe subject assets/property to Favre, then they caused or contributed to causing any alleged hUarm for which recovery of damages is sought by Pohl by selling the alleged trade secrets to Favre. 4 Exhibit 1, Pohl June 19, 2018 Affidavit, at ¶ 28. 5 Exhibit 1, Pohl June 19, 2018 Affidavit, at ¶ 28. 6 Exhibit 1, Pohl June 19, 2018 Affidavit, at ¶¶ 28-29. 7 Pohl’s First Amended Petition, at ¶ 24. 20. Kassab also sufficiently alleged how Pohl’s counsel in the Mississippi litigation, Shepherd, caused or contributed to causing the purported loss or misuse of Pohl’s allegedly confidential information. Specifically, Shepherd negotiated a settlement in thek litigation with Walker, Ladner and Seymour but failed to protect Pohl by ensuring that all sulbject property was gathered from all third parties and returned to Pohl or destroyed as pacrt of the any settlement agreement, if in fact Pohl owned and/or desired to safeguard the subjsect property. 21. Shepherd knew that Walker, Seymour and Ladner had sold Precision to Favre and knew that Walker, Seymour and Ladner had legally transferred Precision’s assets, including the subject matter of Pohl’s conversion and theft of trade secrets claims, to Favre. Shepherd further knew that Favre and/or his counsel had given documents to third parties, including Kassab and others prior to negotiating a settlement in thae Mississippi Litigation. Thus, Shepherd failed to protect Pohl’s alleged trade secrets by failing to include a provision in the settlement agreement forcing all parties to gather the alleeged trade secrets from outside third parties like Kassab so they could be returned to Pohl, fif in fact he owns them as alleged. This failure by Shepherd caused and/or contributed toy causing the harm for which recovery of damages is sought by Pohl. 22. ShepherCd’s malfeasance was either negligent or intentional. If Shepherd knew that the subject asseats/property were a point of contention in the Mississippi Litigation and knew that the assets/pfroperty could be used by outside third parties to garner clients to sue Pohl, as Pohl alleUges, Shepherd may have intentionally failed to protect Pohl’s interest so that he could secure future lucrative employment for himself and his law firm for years to come by continuing to represent Pohl in litigation to be brought against Pohl after the subject property was used to garner clients to sue Pohl as Pohl alleges. Thus, Shepherd is a person who caused or contributed to causing the harm for which recovery of damages is sought by Pohl. 10 23. Finally, Kassab sufficiently alleged how Dona Pohl, Jaimes, Tally and Santana caused or contributed to causing the purported loss or misuse of Pohl’s alleged trade secret information. Specifically, Kassab alleges that these persons failed to keep Pohl’s information confidential because they routinely placed Pohl’s alleged trade secrets and dokcuments in the public domain, circulating Precision’s marketing lists and other documents alllegedly belonging to Pohl to numerous third parties rather than safeguard these documents acnd lists. 24. Additionally, if Walker, Seymour, Ladner, Dona, Jaismes, Talley or Santana had an agreement and/or duty to safeguard any property allegedly owned by Pohl as Pohl alleges, they are responsible for failing to safeguard the property. Additionally, Walker, Seymour, Ladner, Dona, Jaimes, Talley and Santana routinely placed Pohl’s alleged trade secrets and documents in the public domain, circulating Precision’s marketing lists and other documents allegedly belonging to Pohl to numerous thirda parties rather than safeguard these documents and lists.  25. “Under the notice-pleeading standard, fair notice is achieved if the opposing party can ascertain from the pleading tfhe nature and basic issues of the controversy, and what type of evidence might be relevant.y” In re CVR Energy, Inc., 500 S.W.3d at 80. “A trial court may not review the truth of thCe allegations or consider the strength of the defendant's evidence.” Id. Kassab satisfies thais “low threshold” by alleging that the Designated Parties caused or contributed to cfausing the alleged theft or misuse of Pohl’s purported trade secret information. See id. UTherefore, Shepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley, Santana are persons who caused or contributed to causing any alleged harm for which recovery of damages is sought by Pohl. Their conduct caused or contributed to causing in part (if not entirely) the harm for which recovery of damages is sought by Pohl, and that conduct violated an applicable legal standard and/or constitutes negligence. See TEX. CIV. PRAC. & REM. CODE § 33.011(6). Thus, the 11 jury should be permitted to consider apportioning fault in this case to Shepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley, Santana. Their designation as responsible third parties is factually justified and legally appropriate.8 Accordingly, the Court should overrule Pohl’s objection and grant leave to designate the requested third parties. See TEX. CIV.k PRAC. & REM. CODE § 33.004(f) (providing that if pleadings are sufficient, the trial court “s halll grant” leave). IV c PRAYER r For the reasons set forth herein, Defendants, Counter-Plaintiffs, Lance Christopher Kassab and Lance Christopher Kassab, P.C. D/B/A The Kassab Law Firm ask the Court to grant the Kassab Defendants’ Amended Motion to Dersignate Responsible Third Parties and grant all other relief in law or in equity as the Court sees fit and as Defendants, Counter- Plaintiffs will ever pray. i l 8 It is also of no concern here that the Court might be unable to exert personal jurisdiction over either Walker, Seymour, Ladner, Talley, Dona, Jaimes or Santana. In its 2003 revision of Chapter 33, the Legislature abolished the predecessor law, which had defined responsible third parties to be only those over whom the court could exercise jurisdiction, thus allowing the designation of those “who are not subject to the court’s jurisdiction or who are immune from liability to the claimant.” See, e.g., In re Unitec Elevator Serv. Co., 178 S.W.3d 53, 58 & n. 5 (Tex. App.-- Houston [1st Dist.] 2005, orig. proceeding); accord Hix-Hernandez v. Ford Motor Co., No. 1:20-cv-29-RP, 2021 WL 7632564, at *1 (W.D. Tex. May 6, 2021) (“A defendant may designate a responsible third party despite the fact that the party has a defense to liability, cannot be joined as a defendant, or both. Even parties who are outside the court’s jurisdiction or are immune from liability may be designated responsible third parties.”) (internal citations omitted). 12 Respectfully submitted, THE KASSAB LAW FIRM / s / Lance Christopher Kassab LANCE CHRISTOPHER KASSABk Texas State Bar No. 007940r70 lance@kassab.law l DAVID ERIC KASSAB Texas State Bar No. c24071351 david@kassab.lawr NICHOLAS R. PIE s RCE Texas State BDar No. 24098263 nicholas@kassab.law 1214 Elgisn Street Houston, Texas 77004 Teleprhone: 713-522-7400 Facsimile: 713-522-7410 ATTORNEYS FOR THE KASSAB DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that a true aned correct copy of the above and foregoing instrument has been forwarded to all known parties and/or counsel of record pursuant to the Texas Rules of Civil Procedure on this, the 15th off f November, 2022. / s / Lance Christopher Kassab C Lance Christopher Kassab 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. David Kassab Bar No. 24071351 david@kassab.law r Envelope ID: 70189306 Status as of 11/15/2022 1:37 PM CST Case Contacts r i Name BarNumber Email TimestampSubmitted Status Solace Southwick ssouthwick@reynoldssfrizzell.com 11/15/2022 1:31:33 PM SENT Jean C.Frizzell jfrizzell@reynoldgsfrizzell.com 11/15/2022 1:31:33 PM SENT Harris Wells hwells@reynouldsfrizzell.com 11/15/2022 1:31:33 PM SENT Todd Taylor ttaylor@jandflaw.com 11/15/2022 1:31:33 PM SENT Scott M.Favre scott@yfavrepa.com 11/15/2022 1:31:33 PM SENT Lawyer Wade lawayerwade@hotmail.com 11/15/2022 1:31:33 PM SENT Andrea Mendez andrea@kassab.law 11/15/2022 1:31:33 PM SENT Lance Kassab olance@kassab.law 11/15/2022 1:31:33 PM SENT David Kassab david@kassab.law 11/15/2022 1:31:33 PM SENT Jason M.Ciofalo f jason@ciofalolaw.com 11/15/2022 1:31:33 PM SENT Chris C.Pappas cpappas@krcl.com 11/15/2022 1:31:33 PM SENT Todd Taylor p ttaylor@jandflaw.com 11/15/2022 1:31:33 PM SENT Misty Davis C mdavis@reynoldsfrizzell.com 11/15/2022 1:31:33 PM SENT Nicholas Pierce a l nicholas@kassab.law 11/15/2022 1:31:33 PM SENT Murray JFogler mfogler@foglerbrar.com 11/15/2022 1:31:33 PM SENT Murray Fogler o mfogler@fbfog.com 11/15/2022 1:31:33 PM SENT Andrew JohnsUon ajohnson@thompsoncoe.com 11/15/2022 1:31:33 PM SENT Vilma Yanes vyanes@thompsoncoe.com 11/15/2022 1:31:33 PM SENT Benjamin Ritz britz@thompsoncoe.com 11/15/2022 1:31:33 PM SENT Zandra EFoley zfoley@thompsoncoe.com 11/15/2022 1:31:33 PM SENT Dale Jefferson 10607900 jefferson@mdjwlaw.com 11/15/2022 1:31:33 PM SENT Raul Herman Suazo 24003021 suazo@mdjwlaw.com 11/15/2022 1:31:33 PM SENT Kevin Graham Cain 24012371 cain@mdjwlaw.com 11/15/2022 1:31:33 PM SENT D Kassab david@kassab.law 11/15/2022 1:31:33 PM SENT 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: 70189306 Status as of 11/15/2022 1:37 PM CST Case Contacts r i Murray J. Fogler 7207300 mfogler@foglerbrar.com 11/15/2022 1:31:33 PM SENT L Kassab lance@kassab.law s 11/15/2022 1:31:33 PM SENT Murray J. Fogler 7207300 mfogler@foglerbgrar.com 11/15/2022 1:31:33 PM SENT Non-Party Witness Billy Shepherd bshepherd@supcounsel.com 11/15/2022 1:31:33 PM SENT

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