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45 2022-11-22 MTN Kassab 2nd Supp. Motion to Designate RTP Kassab Defendants' Second Supplemental Motion to Designate Responsible Third Parties (Adding Scott Favre and Precision Marketing Group, LLC) Filed November 22, 2022 before Judge Scot Dollinger, 189th Judicial District, Harris County, Texas. Filed 13 days before the December 5, 2022 trial date, after Pohl dismissed Favre and Precision as defendants on November 21, 2022. Kassab seeks good cause to designate newly dismissed parties as responsible third parties within 60 days of trial. RTP-1 N/A Phase 3 2022-11-22_MTN_Kassab-2nd-Supp-Mtn-to-Designate-RTP_FILED.pdf Grant leave to designate Favre and Precision Marketing Group, LLC as additional responsible third parties, in addition to the eight individuals from prior supplemental motion, plus all other relief in law or equity 11/22/2022 3:51 PM Marilyn Burgess - District Clerk Harris County Envelope No. 70416484 By: Ashley Lopez Filed: 11/22/2022 3:51 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 SECOND SUPPLEMENTAL MOTION TO DESIGNATE RcESPONSIBLE THIRD PARTIES r TO THE HONORABLE JUDGE SCOT DOLLINGER: D Defendants, Lance Christopher Kassab and Lance Chsristopher Kassab, P.C. D/B/A The Kassab Law Firm (“Kassab”), and file this, their Secornd Supplemental Motion to Designate Responsible Third Parties. REQUEaSTED RELIEF 1. Kassab files this Second Supplemental Motion to Designate Responsible Third Parties to add Scott Favre (Favre) aned Precision Marketing Group, LLC (Precision) as additional third parties. Favre and Precisionf were defendants in this lawsuit until Plaintiffs dismissed them on November 21, 2022, jusyt 14 days prior to trail. Thus, Favre and Precision are no longer parties to this suit. ThCus, there is good cause for designating Favre and Precision as responsible Third Parties withina 60 days of trial due to the timing of Plaintiffs nonsuit of these parties. 2. Ffavre and Precision are central to this litigation as they purchased all of the material Uand documents, which are the subject of Plaintiffs’ complaints, from Walker, Ladner and Seymour, who previously owned Precision. Favre and Precision then gave some of the material and documents to Kassab to notify Precision’s clients regarding Pohl’s illegal conduct and potential claims they may have against Pohl. Thus, Favre and Pohl are central to this litigation and are subject to potential third party liability, if there is liability at all. 3. Favre and Precision are outside of the subpoena power of this court. Although Kassab has attempted to depose Favre and Precision for more than a year, Kassab has been unsuccessful due to no fault of Kassab. Now that Plaintiffs have dismissed their claims against Favre and Precision, Kassab cannot rely on Favre and Precision showing up to kthe trial in this matter. l II c FACTS r 4. Pohl is a lawyer who commits barratry and has pDrayed on the less fortunate to earn a living. On October 18, 2014, three Mississippi residensts, Scott Walker (“Walker”), Kirk Ladner (“Ladner”) and Steve Seymour (“Seymour”),r and their related entities, including Precision Marketing Group, LLC (“Precision”), filed suit against Michael Pohl (“Pohl”) and others in Mississippi federal court (the “Misslissippi Litigation”). There, Precision, Walker, Ladner and Seymour alleged that: (1) theyM had a joint venture with Pohl to sign up clients with economic loss claims stemming fromo the BP Deepwater Horizon oil spill and clients with personal injury claims; (2) that they successfully obtained these clients for Pohl; and (3) that Pohl breached their agreement by not paying them what was owed, including their agreed share of Pohl’s attorney’s fees. 5. The evidence presented in the Mississippi Litigation established that Pohl engaged in barractry. See TEX. PEN. CODE § 38.12 (defining barratry 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 himself 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 other lawyers to solicit potential clients, both auto-accident victims and those involved in the BP litigation. They would use this money to pay contract workers to solicit clients. They would locate and instruct contract workers on how to accomplish the solicitation. They trained “40 or 50 people” on how to “go out and solicit conktracts.” 6. Walker and his team at Precision were first retained by Pohl lto “recruit clients” with losses resulting from the Deepwater Horizon oil spill. When that lcitigation dwindled, Pohl shifted his focus to auto accident cases, knowing that the group at Prsecision 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 – whaere 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 eeach individual runner. Walker would simply submit to Pohl the amount that Precision paid itsf runners and Pohl would reimburse Precision. 7. One of the ruynners, Santana, testified to the barratry in her September 24, 2016 affidavit filed in the MCississippi Litigation. She testified that Pohl sent her on “dozens and dozens of car wrecak cases all over the country.” Pohl would email Santana the link of news coverage depictfing the accident and ask her “to go to the victim or the victim’s family and try to get them Uto 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 the 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 barratry.” According to Pohl, they “were easier to sign up.” 8. Pohl would pay Santana “money to give to the victims or their families” but “only if they agreed to sign a Pohl representation contract.” Pohl advised Santana that thke money was a “foot in the door” but instructed Santana not to mention that she was there onl behalf of a lawyer “until after they agreed to take the money.” “If the client agreed to hire Pcohl, then [Santana] was to have the client sign a ‘Helping Hands’ contract.” Pohl would thens give Santana the money to pay 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.” 9. Santana further confirmed the barratry in her deposition taken in the Mississippi Litigation. She testified that she was hired bay 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,e to personally visit the mother of the deceased and sign her up to sue the tire manufacturer anfd, if she succeeded, Pohl would pay her $5,000. Santana visited the funeral of the deceased aynd got the family to feel comfortable with her. Although the mother was grieving, Pohl toldC Santana: “take no prisoners, this is a cut-throat business, you get in there and you do whatevaer it takes to get this client.” The solicitation was successful after Pohl gave Santana $2,000 fto “give to the client to convince her into signing over with the firm.” 10U. 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 this in his deposition. Santana signed the statement and received the cash, although she believed she was “forced to sign” it while “under duress”. 11. Another runner, Talley, also testified in the Mississippi Litigation about the barratry. Talley solicited over 20 auto accident cases for Pohl, including two famkilies who hired Kassab to sue Pohl for barratry. Talley testified that he was first hired in relatilon to BP claims to find “folks that lost money due to the oil spill” and “sign them up” and “cget a fee for it.” Talley solicited and signed up more than 800 BP claims for Pohl and was spaid between $75 and $350 per client.  12. 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 lawyaer, 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 attorneyse was Pohl. For each auto accident case he solicited, Talley was paid a fee of $1,400 plus hfis expenses by Pohl, through Walker and Precision. On some cases, Talley was to receive ya portion of Pohl’s attorney’s fees, and even discussed with Pohl the “percentage of settlemCents” he was to receive. When asked whether Pohl knew he was getting paid to “contact vaehicle accident victims,” Talley responded, “the money was coming from Edgar [Jaimes] fwho worked for him.” 1CR301. Although his paycheck was from Precision, “the funding cUame by way of Edgar [Jaimes].” Talley testified that both he and Pohl knew what they were doing was illegal. 13. 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 Litigation, 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 lawyer, Tina Nicholson and her firm, Baker Nicholson, LLP (“Nicholson”). Pohl asserted counter claims in the Mississippi Litigation allegikng that Walker and Precision (and other unknown defendants) converted his property. Polhl then moved to dismiss the claims against him, arguing, among other things, that the acgreements between him and the runners were illegal and unenforceable. More specifically, sPohl argued that under both Texas and Mississippi law “it is illegal for a non-lawyer to accept or agree to accept money to improperly 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 failead to obtain summary dismissal, Pohl settled the Mississippi Litigation with all parties, including Favre, hoping to forever conceal his barratry operation. Although Pohl had alreaedy paid the runners approximately $5,000,000 in barratry money, Pohl paid the runners an fadditional $1,000,000 to settle the Mississippi Litigation. 14. Kassab heardy about the allegations being made by the runners in the Mississippi Litigation. Kassab seaCrched PACER, the federal court’s online system, obtaining a plethora of information relateda to the Mississippi Litigation. Kassab met with Favre and Precision’s counsel, Nicholfson. Kassab obtained information directly from them, including the names and addressesU of Pohl’s former clients or prospective clients from Precision’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 had 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 against Pohl and other lawyers involved in the illegal barratry scheme. k 15. Kassab filed four petitions on behalf of these barratry victimsl in Harris County, Texas (the “barratry lawsuits”). The barratry lawsuits communicated mcatters of public concern: that Pohl conspired to commit barratry. After reviewing the esvidence obtained from the Mississippi Litigation, Kassab believed he had a duty to file a grievance against Pohl pursuant to Rule 8.03 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 client expressed matters of public concern relating to Pohl’s legal services in the marketplace and petitioned the State Bar of Texas to reprimanad and discipline Pohl in order to protect the public as is mandated by Rule 8.03.  16. Unfortunately, in direect retaliation to the lawsuits and grievances filed against Pohl, Pohl filed this retaliatoryf litigation against Kassab, Precision, Nicholson, Favre and Montague, alleging breach yof contract, theft of trade secrets, conversion and civil conspiracy. Specifically, Pohl alleCged that these parties were “acting in combination with the agreed objective” to misapapropriate his trade secrets and convert the marketing lists and attorney-client contracts that Pfohl hired Precision to obtain. Pohl alleges Favre and Precision, with Nicholson’s assistanceU, 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.” 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.”). III ARGUMENT 17. “A defendant may seek to 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 caruse to allow the motion to be filed at a later date.” TEX. CIV. PRAC. & REM. CODE § 33.0 04(a). That occurred here, with Kassab filing his motion on May 13, 2022, more than 60 darys before the October 10, 2022 trial setting. The current trial setting is December 5, 2022.D Thus, the statute required the Court to “grant leave to designate the named person as a ressponsible third party unless another party files an objection to the motion for leave on or beforre the 15th day after the date the motion is served.” Id. at § 33.004(f). 18. Kassab has good cause to desiglnate Favre and Pohl within 60 days of trial because Plaintiff just dismissed Favre andM Pohl from this lawsuit 14 days prior to the current scheduled trial. Kassab will be prejuodiced if Kassab is not allowed to designate Favre and Precision at this late time due to the circumstances created by Plaintiff and at no fault of Kassab. 19. A responsible third party is “any person who is alleged to have caused or contributed to causing in any way the harm for which recovery of damages is sought, whether by negligent act or omission, by any defective or unreasonably dangerous product, by other conduct or activity that vciolates 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 contributed to causing “in any way” the loss of or eventual 2 Pohl RTP Objection, at 2. alleged misuse of purported trade secret information. See In re CVR Energy, Inc., 500 S.W.3d 67, 80 (Tex. App.—Houston [1st Dist.] 2016, no pet.) (“The standard for designating a potentially responsible third party is notice pleading under the Texas Rules of Civil Procedure.”). 20. Kassab alleged that Walker, Ladner and Seymour are responsiblke for the harm alleged to the extent they misappropriated Pohl’s trade secrets in the first instalnce and sold them to Scott Favre and transferred Precision to Favre, who Pohl alleges thecn sold his alleged trade secrets to Kassab to pursue the barratry litigation. In fact, Pohl himsself, swore under oath that Walker, Lander and Seymour, who Pohl identified collectively 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 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 informationa 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 infoermation and supporting materials.”5 Pohl testified that this purportedly trade secret informfation was delivered or sold Walker, Ladner and Seymour “without his consent” to Fyavre.6 Pohl alleges in this lawsuit that Favre then sold that same information to KassabC to pursue barratry claims against Pohl.7 If any loss or eventual misuse of Pohl’s purported traade secret information did occur, Walker, Ladner and Seymour clearly caused or contributed tfo causing it, as had Walker, Ladner and Seymour not stolen Pohl’s alleged trade secrets asU 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. 3 Exhibit 1, Pohl June 19, 2018 Affidavit, at ¶ 18. 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. 21. Additionally, if any loss or eventual misuse of Pohl’s purported trade secret information occurred, Favre and Precision clearly caused or contributed to causing it, as Favre and Precision certified and represented to Kassab that all of the material and documents given to Kassab by Favre and Precision were owned by Favre and Precision after purchasking these items from Walker, Ladner and Seymour. Walker, Ladner and Seymour certified land represented to Favre that they owned all of the subject material when they sold it cand Precision to Favre. Kassab relied on these representations when Kassab was given thes subject documents. Thus, Kassab could not have misappropriated any alleged trade secret by improper means. 22. Walker testified under oath that he, Seymour and Ladner, through Precision, owned all the assets/property, including computers and documents that were transferred to Favre. Walker also testified that he had the legal right and authority, through Precision, to sell and transfer all the subject assets/property to Faavre. Moreover, Walker, Seymour and Ladner certified that they owned all of the subject property/assets and had authority to transfer all of the subject property/assets to Favre. If Wealker, Seymour and Ladner did not have the legal right to transfer all of the subject assets/pfroperty to Favre, then they caused or contributed to causing any alleged harm for which recyovery of damages is sought by Pohl by selling the alleged trade secrets to Favre. C 28. “Undaer the notice-pleading standard, fair notice is achieved if the opposing party can ascertain frfom the pleading the nature and basic issues of the controversy, and what type of evidence Umight be relevant.” In re CVR Energy, Inc., 500 S.W.3d at 80. “A trial court may not review the truth of the allegations or consider the strength of the defendant's evidence.” Id. Kassab satisfies this “low threshold” by alleging that the Designated Parties caused or contributed to causing the alleged theft or misuse of Pohl’s purported trade secret information. See id. Therefore, Shepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley, Santana are 10 persons who caused or contributed to causing any alleged harm for which recovery of damages is sought by Pohl. Additionally, Favre and Precision are also 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 recovkery of damages is sought by Pohl, and that conduct violated an applicable legal standard land/or constitutes negligence. See TEX. CIV. PRAC. & REM. CODE § 33.011(6). Thus, the jcury should be permitted to consider apportioning fault in this case to Favre, Precision, Sshepherd, Walker, Seymour, Ladner, Dona, Jaimes, Talley, Santana. Their designation as responsible third parties is factually justified and legally appropriate.8 PRAYER For the reasons set forth herein, Defielndants, 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’ Motion to Designate Responsible Third Parties, in addition to the Supplements, and grant all otheir relief in law or in equity as the Court sees fit and as Defendants, Counter-Plaintiffs will forever pray. 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). 11 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 22nd of f f November, 2022. / s / Lance Christopher Kassab C Lance Christopher Kassab 12 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: 70416484 Status as of 11/22/2022 3:54 PM CST Case Contacts r i Name BarNumber Email TimestampSubmitted Status Solace Southwick ssouthwick@reynoldssfrizzell.com 11/22/2022 3:51:15 PM SENT Jean C.Frizzell jfrizzell@reynoldgsfrizzell.com 11/22/2022 3:51:15 PM SENT Harris Wells hwells@reynouldsfrizzell.com 11/22/2022 3:51:15 PM SENT Todd Taylor ttaylor@jandflaw.com 11/22/2022 3:51:15 PM SENT Scott M.Favre scott@yfavrepa.com 11/22/2022 3:51:15 PM SENT Lawyer Wade lawayerwade@hotmail.com 11/22/2022 3:51:15 PM SENT Andrea Mendez andrea@kassab.law 11/22/2022 3:51:15 PM SENT Lance Kassab olance@kassab.law 11/22/2022 3:51:15 PM SENT David Kassab david@kassab.law 11/22/2022 3:51:15 PM SENT Jason M.Ciofalo f jason@ciofalolaw.com 11/22/2022 3:51:15 PM SENT Chris C.Pappas cpappas@krcl.com 11/22/2022 3:51:15 PM SENT Todd Taylor p ttaylor@jandflaw.com 11/22/2022 3:51:15 PM SENT Misty Davis C mdavis@reynoldsfrizzell.com 11/22/2022 3:51:15 PM SENT Nicholas Pierce a l nicholas@kassab.law 11/22/2022 3:51:15 PM SENT Murray JFogler mfogler@foglerbrar.com 11/22/2022 3:51:15 PM SENT Murray Fogler o mfogler@fbfog.com 11/22/2022 3:51:15 PM SENT Andrew JohnsUon ajohnson@thompsoncoe.com 11/22/2022 3:51:15 PM SENT Vilma Yanes vyanes@thompsoncoe.com 11/22/2022 3:51:15 PM SENT Benjamin Ritz britz@thompsoncoe.com 11/22/2022 3:51:15 PM SENT Zandra EFoley zfoley@thompsoncoe.com 11/22/2022 3:51:15 PM SENT Dale Jefferson 10607900 jefferson@mdjwlaw.com 11/22/2022 3:51:15 PM SENT Raul Herman Suazo 24003021 suazo@mdjwlaw.com 11/22/2022 3:51:15 PM SENT Kevin Graham Cain 24012371 cain@mdjwlaw.com 11/22/2022 3:51:15 PM SENT D Kassab david@kassab.law 11/22/2022 3:51:15 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: 70416484 Status as of 11/22/2022 3:54 PM CST Case Contacts r i Murray J. Fogler 7207300 mfogler@foglerbrar.com 11/22/2022 3:51:15 PM SENT L Kassab lance@kassab.law s 11/22/2022 3:51:15 PM SENT Murray J. Fogler 7207300 mfogler@foglerbgrar.com 11/22/2022 3:51:15 PM SENT Non-Party Witness Billy Shepherd bshepherd@supcounsel.com 11/22/2022 3:51:15 PM SENT

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