filings: 59

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59 2023-09-15 OBJ Kassab Objection to proposed final judgment Kassab's Objections to Pohl's Proposed Final Judgment, challenging exemplary damages, recoverability of attorneys' fees as actual damages, double recovery of unjust enrichment and market value, joint and several liability based on conspiracy, and indirect misappropriation theory Filed September 15, 2023 in the 281st Judicial District Court, Harris County, Cause No. 2018-58419. Filed 10 days after Pohl's Motion for Entry of Final Judgment, objecting to specific elements of the proposed judgment while reserving right to file subsequent motions challenging jury findings on other grounds. New appellate counsel Kevin Dubose (Alexander Dubose & Jefferson LLP) appears for Kassab. JDGMT-1 N/A Phase 5 2023-09-15_OBJ_Kassab-Objection-to-Pohl-Proposed-Final-Judgment_FILED.pdf That the Court refrain from signing Pohl's proposed final judgment and exclude: (1) exemplary damages ($3,000,000) due to non-unanimous Q17 finding, (2) attorneys' fees from barratry cases and grievances as actual damages, (3) one of the duplicative damage measures ($250,000 market value or $200,000 development costs), (4) joint and several liability based on conspiracy, and (5) all damages given Precision's exoneration breaking the indirect misappropriation chain 9/15/2023 1:38 PM Marilyn Burgess - District Clerk Harris County Envelope No. 79605741 By: Patricia Gonzalez Filed: 9/15/2023 1:38 PM CAUSE NO. 2018-58419 MICHAEL A. POHL, et al § IN THE DISTRICT COURT V. § OF HARRIS COUNTY, TEXAS § k § e SCOTT FAVRE, et al § 281st JUDICCIAL DISTRICT KASSAB’S OBJECTIONS TO POHL’S PROPOSED FINAL JUDGMEtNT Lance Christopher Kassab and Lance Christopher Kassab, P.C. d/b/a The Kassab Law Firm (“Kassab”) file these Objection teo the proposed Final Judgment submitted by Plaintiffs Michael Pohl and uLaw Office of Michael A. Pohl PLLC’(“Pohl”). INTRODUCTIOaN AND OVERVIEW Kassab will file subsequent motions challenging the jury findings against him on various grounds. But this filineg will be limited to objecting to elements of recovery in Pohl’s proposed judgmenft that are legally insupportable, even with these jury findings. Specifically: • The judgment should not include exemplary damages because one of the predicate ifindings for exemplary damages was not answered by the jury unanoimously. • The judgment should not include as actual damages attorney’s fees incurred by Pohl in actions against him by former clients and rejected potential clients who were victims of Pohl’s barratry. Attorney’s fees are not an element of recoverable damages under TUTSA. • The judgment should not include actual damages for both unjust enrichment of Kassab and the fair market value of the alleged trade secret misappropriated from Pohl because they are two impermissibly overlapping versions of the same loss. Pohl should have to elect one of those remedies rather than being awarded a double recovery. C • The judgment should not include joint and several liabili i ty under a conspiracy theory because conspiracy is pre-empted under TUTiSA or subject to Chapter 33’s proportionate responsibility scheme. • The judgment should not include any actual damages for theft of trade secrets because of the jury’s findings that Precision did not misappropriate trade secrets. Because Kassab acquired Plohl’s alleged trade secrets from Precision, and the jury found that PrecMision acquired the information lawfully, then Kassab could not have misappropriated trade secrets from Pohl. i ARGUMENT I. The judgment should not include exemplary damages because the predicate question to reach the exemplary damages question was onot answered unanimously. Question 19l was the only question in the jury charge that asked about exemplary damiages. The predicate instruction for Question 19 said, “Answer the following question only if you unanimously answered ‘Yes’ to Question No. 17 or Question No. 18. Otherwise, do not answer the following question.”1 The jury did not answer Question 18. 1 Motion, Exhibit A, at Question 19. Some members of the jury answered Question 17 ‘Yes,” finding that the misappropriation of trade secrets was willful and malicious.2 But the answer to Question 17 was not unanimous — contrary to Pohl’s erroneous and false assertion that “the jury unanimously found that the misappropriation of Pohl’s ktrade secrets by Kassab was willful and malicious.”3 C The certificate at the end of the jury verdict makes it unmistakably clear that the answer to Question 17 was not unanimous. First, in thie general part of the jury certificate the jury declined to check the box indicating that “Our verdict is unanimous,” but instead checked the box indicating that ten jurors agreed to every answer: The additional certificate requcired the jury to indicate whether certain liability and damages questions were answered unanimously: In respoUnse to that instruction, the presiding juror signed certificates indicating that Questions 2 and 19 were unanimous. But the presiding juror conspicuously did not 2 Motion, Exhibit A, at Question 17. 3 Motion, at 3. sign the certificate for Question 17: Thus, the jury’s answer to Question 17 was unmistakably not iunanimous. The jury’s failure to answer Question 17 unanimouDsliy precludes any award of exemplary damages by both rule and statute. See TEXs. R. CIV. P. 292 (“A verdict may be rendered awarding exemplary damages only ifr the jury was unanimous in finding liability for and the amount of exemplary d amages.”) (emphasis added); TEX. CIV. PRAC. & REM. CODE § 41.003(d) (“Exempl alry damages may be awarded only if the jury was unanimous in regard to finding liability for and the amount of exemplary damages.”) (emphasis added). Texas cases have not heisitated to apply this principle articulated in both rule and statute. See Redwine v. Peckinpaugh, 535 S.W.3d 44, 52 (Tex. App.—Tyler 2017, no pet.) (concluding o“that the trial court erred in entering judgment awarding exemplary damaagles” when “[d]espite [the jury] having answered the exemplary damages quesftiion, which was predicated on its unanimously having found that [the defendant] made multiple defamatory statements, the jury stated in the charge that its verdict was not unanimous.”); DeAtley v. Rodriguez, 246 S.W.3d 848, 850 (Tex. App.—Dallas 2008, no pet.) (trial court did not err in reforming a judgment where Rule 292 required a unanimous jury finding both liability for and the amount of exemplary damages; a non-unanimous verdict on liability was insufficient as a matter of law to support an award of exemplary damages). Because the predicate finding of malicious misappropriation was the only way to get to exemplary damages, and that question was not answered unaknimously, the judgment cannot include exemplary damages. C II. The judgment should not include attorney’s fees incurred in Pohl barratry cases and grievance procedures betcause they are not recoverable under TUTSA or the Disciplinairy Rules. A. Attorney’s fees incurred in Pohl’s barratry cases and grievances are not recoverable undeer TUTSA. Attorney’s fees incurred by Pohl in defenuding barratry suits and grievances filed by his former clients and rejected potential clients are not recoverable under TUTSA. TUTSA provides recovery for a“actual loss[es] caused by misappropriation” and unjust enrichment. TEX. CIV. PRAC. & REM. CODE § 134A.004. The act does not define that term, and no Texase case has attempted a definition. However, the act requires it to “be applied anfd construed to effectuate its general purpose to make uniform the law with respect to the subject of this chapter among states enacting it.” TEX. CIV. PRAC. & REM. CODE § 134A.008. Thus, the Court must look to and be guided by decisions fromi other states that have adopted the Uniform Trade Secrets Act. See Morgan v. Colements Fluids S. Tex., Ltd., 589 S.W.3d 177, 191 n.4 (Tex. App.—Tyler 2018, no pet.) (looking to Florida law when interpreting TUTSA because “[t]he Florida Uniform Trade Secrets Act is very similar to the TUTSA”). Courts in other jurisdictions “have made clear that ‘actual loss’ means ‘loss of profits, lost customers or lost market share.’” K3 Enter., Inc. v. Sasowski, No. 20- 24441-CIV-CAN, 2022 U.S. Dist. LEXIS 234206, at *10 (S.D. Fla. 2022) (concluding reputational damage was not an “actual loss” under Florida’s Uniform Trade Secrets Act) (citing Fin. Info. Techs., LLC v. iControl Sys., USA, LLC, 21 F.4th 1267, 1276 (11th Cir. 2021) (understanding “actual loss” in terms of lost profits); Skelectica, Inc. v. Novatus, Inc., No. 6:13-cv-1708-Orl-40TBS, 2015 U.S. Dist. LECXIS 191940, at *9 (M.D. Fla. 2015) (“‘Actual loss’ has been defined as ‘loss of profits, lost customers or lost market share.’”). In a case construing the Idaho Uniforim Trade Secrets Act, the Idaho Supreme Court held that actual loss means “lost profits, lost customers, lost market share, and similar losses,” but specifically held that “it would be an anomaly for us to allow attorney fees to be recovered in a case like this as part of damages.” GME, Inc. v. Carter, 917 P.2d 754, 757 (Idalho 1996). Thus, attorney’s fees that Pohl incurred defending the barratry claimMs and grievances brought against him are not actual losses recoverable under the statute. This conclusion is consiistent with Texas trade secret law before TUTSA. The Supreme Court of Texas defined recoverable losses for a trade secret claim as “the value of the plaintiff’so lost profits, the defendant’s actual profits from the use of the secret, the value al reasonably prudent investor would have paid for the trade secret, the developmient costs the defendant avoided by the misappropriation, and a reasonable royalty.” Sw. Energy Prod. Co. v. Berry-Helfand, 491 S.W.3d 699, 710–11 (Tex. 2016); see also Carbo Ceramics, Inc. v. Keefe, 166 F. App'x 714, 722-23 (5th Cir. 2006) (“In an action for trade secret misappropriation, the plaintiff may recover actual damages based on either the value of what has been lost by the plaintiff or the value of what has been gained by the defendant. … The value of what has been lost by the plaintiff is usually measured by lost profits.”) (applying Texas law) (emphasis added). No Texas court has ever allowed attorneys’ fees in other cases to be recovered as actual damages in a trade secret claim. In fact, at leakst one recent Texas court has concluded the opposite in dismissing a TUTSA Cclaim. See Lacore Enters., LLC v. Angles, No. 05-21-00798-CV, 2023 Tex. App. LEXIS 1926, at *32-33 (Tex. App.—Dallas Mar. 23, 2023, no pet. h.) (mem. op.) (irejecting contention that “disclosure of [party’s] confidential information” caused “the attorney’s fees that have been incurred [which] is evidence of damages” because “attorney’s fees incurred in a lawsuit are not actual damages.”). This conclusion is further reinforceld by Texas law regarding attorney’s fees incurred in previous litigation. “[F]eeMs expended in prior litigation generally are not recoverable as damages; fees are recoverable only when an agreement between the parties so provides.” Martin-Siimon v. Womack, 68 S.W.3d 793, 797 (Tex. App.— Houston [14th Dist.] 2001, pet. denied); see also Tana Oil & Gas Corp. v. McCall, 104 S.W.3d 80, 81-82 (Texo. 2003) (attorney’s fees for defending a different claim are not recoverable as damlages as a matter of law); O'Neal v. Dale, No. 02-20-00173-CV, 2021 Tex. App. LEXiIS 466, at *28 (Tex. App.—Fort Worth Jan. 21, 2021, no pet.) (mem. op.) (“a party's claim that he incurred attorney’s fees to defend against [another] claim is not a viable damage claim.”); Tex. Mut. Ins. Co. v. Ray Ferguson Interests, Inc., No. 01-02-00807-CV, 2006 Tex. App. LEXIS 2001, at *23-24 (Tex. App.—Houston [1st Dist.] Mar. 16, 2006, pet. denied) (mem. op.) (“financial loss due to time spent by [party] on litigation matters” in another case was not, as a matter of law, recoverable). And the law is clear that “[a] party relying on assertions of non-recoverable damages alone, such as attorney’s fees and expenses sustained in defending a lawsuit . . . has presented a legal barrier to any recovery.” Woodhaven Partners Ltd. vk. Shamoun & Norman, L.L.P., 422 S.W.3d 821, 837 (Tex. App.—Dallas 2014, no Cpet.). Pohl may argue that he is entitled to recover attorney’s fees based on an exception to the general rule based on the “tort of another,” wihich provides that “[o]ne who through the tort of another has been required to act in the protection of his interests by bringing or defending an action against a third person is entitled to recover reasonable compensation for loss of time, attorney fees and other expenditures thereby suffered or incurredl in the earlier action.” Naschke v. Gulf Coast Conference, 187 S.W.3d 653, 6M55 (Tex. App.—Houston [14th Dist.] 2006, pet. denied) (quoting RESTATEMENT (SECOND) OF TORTS § 914 (1979)). But that exception has never been embraced by tihe Texas Supreme Court4 and has been flatly rejected by the Fourteenth Court of Appeals.5 See Naschke, 187 S.W.3d at 655 (“Because we are bound to follow thoe existing laws of the State, we are not at liberty to adopt a 4 See Akin, Gum f pi, Strauss, Hauer & Feld, L.L.P. v. Nat’l Dev. & Research Corp., 299 S.W.3d 106, 119 (Tex. 2009) (“o[W]e need not and do not address whether the exception set out in section 914(2) of the Second Restnatement should be adopted as Texas law.”). 5 Other intermediate courts of appeals have likewise refused to adopt the tort of another doctrine. Riner v. Neumann, 353 S.W.3d 312, 323 (Tex. App.—Dallas 2011, no pet.) (“Given the supreme court’s faithful adherence to the American Rule, and its strong statement in Tony Gullo that trial courts lack the inherent authority to award fees contrary to the Rule, we decline to adopt a new equitable exception to the Rule.”); TOKA Gen. Contractors v. Wm. Rigg Co., No. 04-12-00474-CV, 2014 Tex. App. LEXIS 3776, at *20 (Tex. App.—San Antonio Apr. 9, 2014, pet. denied) (mem. op.) (collecting cases); Per-Se Techs., Inc. v. Sybase, Inc., No. 01-03-01293-CV, 2005 Tex. App. LEXIS 5096, at *24 (Tex. App.—Houston [1st Dist.] June 30, 2005, no pet.) (mem. op.) (collecting cases). theory of recovery that has not been enacted by the Legislature or adopted by the Texas Supreme Court.”). The First Court of Appeals has not specifically held whether the “tort of another” exception is viable. But it has stated that because this exkception is an equitable doctrine it can only apply when the plaintiff is “whollyC innocent” of any wrongdoing. See Per-Se Techs., Inc. v. Sybase, Inc., No. 01-03-01293-CV, 2005 Tex. App. LEXIS 5096, at *24 (Tex. App.—Houston [1st Dist.]i June 30, 2005, no pet.) (mem. op.); see also Brannan Paving GP, LLC v. Pavement Markings, Inc., 446 S.W.3d 14, 27 (Tex. App.—Corpus Christi 2013, pet. denied) (referring to the “tort of another exception” as an “equitable exception” to the general rule). Here, the jury concluded in responsel to Question 3 that the “wrongful conduct of Pohl . . . contribute[d] to the injury.M”6 Because Pohl is not a wholly innocent party, he may not invoke the “tort of another exception” to the general rule even if it is a viable doctrine under Texas laiw. See Per-Se Techs., 2005 Tex. App. LEXIS 5096, at *24; see also Pacesetter Pools, Inc. v. Pierce Homes, Inc., 86 S.W.3d 827, 834 (Tex. App.—Austin 2002, noo pet.) (“[B]ecause the jury found that Allcox's damages were caused by the neglligent conduct of both Pierce Homes and Pacesetter, equitable principles do niot allow Pierce Homes to recover its previously incurred attorney’s fees as damages.”); Dayton Hudson Corp. v. Eldridge, 742 S.W.2d 482, 488 (Tex. App.— Dallas 1987, writ denied) (“[I]n the present case, Eldridge is not an innocent party forced to incur costs and expenses, including attorneys' fees, to be treated as the legal 6 Motion, at Exhibit A, at Question No. 3. consequences of some original wrongful act of another and permitted to be recovered as damages.”). Accordingly, attorney’s fees incurred by Pohl in defending against barratry litigation and grievances are not recoverable “actual losses” under TUTSkA and should not be included in the judgment. C B. Attorneys’ fees are never recoverable against persons bringing grievance procedures. t Rule 17.09 of the Texas Rules of Disciplinary Procedure provides immunity to persons filing grievance procedures: “No lawsuit emay be instituted against any Complainant or witness predicated upon the filinug of a Grievance or participation in the attorney disciplinary and disability system . . . . The immunity is absolute and unqualified and extends to all actions ata law or in equity.” TEX. R. DISC. P. 17.09. Even “allegations of wrongdoing . . . in connection with [the] prosecution of disciplinary actions” are absolutely immune,e so long as they are “predicated upon” the filing of a grievance. Crampton v. Farfris, 596 S.W.3d 267, 274-75 (Tex. App.—Houston [1st Dist.] 2019, no pet.). Thus, the $112,286 in attorney’s fees for defending against grievances that the jury found in Quiestion 7(1)(e) and 7(1)(f) and are not recoverable damages as a matter of law. See ToEX. R. DISC. P. 17.09. III. The judgment should not include damages for both unjust enrichment and fair market value; Pohl should have to elect between the two. Under TUTSA, a claimant is entitled to recover “actual loss caused by the misappropriation and unjust enrichment caused by misappropriation that is not 10 taken into account in computing actual loss.” TEX. CIV. PRAC. & REM. CODE §134A.004. Pohl’s request for judgment seeks an improper double recovery. In response to Question 7(2) the jury found $250,000 in damages for actual loss, that is, the price a willing buyer and a willing seller would have agreed on, at the time okf the alleged misappropriation, as a fair price for Kassab’s use of the allegedC trade secrets. In response to Question 7(3), the jury found $200,000 in unjust enrichment damages, that is, the value of the development costs that Kassiab avoided by allegedly misappropriating Pohl’s trade secrets. If Pohl recovers the fair market value of his alleged trade secrets he will be fully compensated for any actual loss. If he were willing to sell the alleged secrets to a third party, that buyer would necessarilyl possess the secrets and would avoid any development costs as part of the acqMuisition. Therefore, the development costs are “taken into account” in the market value and duplicate the fair market value. TEX. CIV. PRAC. & REM. CODE § 134Ai.004. In other words, Pohl cannot recover both of these duplicative elements of damages under TUTSA but should be required to make an election between the towo. IV. The judgmlent should not include joint and several liability under a iconspiracy theory because conspiracy is pre-empted under TiUTSA or subject to proportionate responsibility under Chapoter 33. Pohl’s proposed judgment includes joint and several liability against Kassab based on a conspiracy finding by the jury in Question 15. But Pohl’s conspiracy claim is either preempted by TUTSA or subject to the proportionate responsibility scheme of Chapter 33 of the Texas Civil Practice & Remedies Code. 11 With respect to TUTSA, the act provides that it “displaces conflicting tort, restitutionary, and other law of this state providing civil remedies for misappropriation of a trade secret.” TEX. CIV. PRAC. & REM. CODE §134A.007. Although no Texas case has addressed this issue, a federal district cokurt sitting in Texas has concluded that “the weight of authority from district courCts within the Fifth Circuit … [demonstrate a] conspiracy claim is preempted by TUTSA.” VEST Safety Med. Servs., LLC v. Arbor Env't, LLC, No. 4:20-CV-0812i, 2022 U.S. Dist. LEXIS 127285, at *10 (S.D. Tex. 2022) (collecting cases). With respect to Chapter 33, it applies to “any cause of action based on tort in which a defendant, settling person, or responsible third party is found responsible for a percentage of the harm for which relief ils sought.” TEX. CIV. PRAC. & REM. CODE § 33.002(a). “Civil conspiracy is an inMtentional tort.” Firestone Steel Prods. Co. v. Barajas, 927 S.W.2d 608, 617 (Tex. 1996). Chapter 33 lists those claims to which it does not apply and does not lisit conspiracy. See id. at § 33.002(c). Accordingly, courts have concluded that Chapter 33’s proportionate responsibility scheme applies to conspiracy claims, ratoher than joint and several liability. See Seven Seas Petroleum, Inc. v. Cibc World lMkts. Corp., No. H-08-3048, 2013 U.S. Dist. LEXIS 101112, at *73- 74 (S.D. Tex. i2013) (“when the Legislature has chosen to impose joint and several liability rather than proportionate liability, it has clearly said so.”); Pemex Exploracion Y Produccion v. BASF Corp., No. H-10-1997, 2011 U.S. Dist. LEXIS 156655, at *43-48 (S.D. Tex. 2011) (claims for conspiracy are not expressly exempted from Chapter 33's proportionate responsibility framework). 12 Because the conspiracy claim is either preempted by TUTSA or subject to the proportionate responsibility scheme under Chapter 33, the judgment should not include joint and several liability against Kassab. V. The judgment should not include any damages against Kkassab because the jury’s finding of no wrongdoing by Perecision destroys the misappropriation claim against Kassab. C Pohl alleged that Precision illegally misappropriated trade secrets from him, and that Kassab subsequently committed indirect misappriopriation of trade secrets by acquiring illegally misappropriated trade secrets from Precision.7 Although Pohl originally sued Precision, he non-suited his claims against Precision. Nevertheless, Precision was designated as a responsible third party, and when the jury was asked whether Precision misappropriated trade lsecrets from Pohl, it found that Precision did not.8 In consistent fashion, the juryM answered “0” in Question 4 when asked to assign what percentage of the “fault that caused the o injury” was attributable to Precision.9 Indirect misappropriation of trade secrets has been described as a “daisy- chain” type liability in that the plaintiff must show “that the defendant knew or had reason to knowo before the use or disclosure that the information was a trade secret and knew olr had reason to know that the disclosing party had acquired it 7 Plaintiff’s nFirst Amended Petition, at ¶ 21 (“Favre and Precision illegally misappropriated Pohl’s prUoprietary and confidential information and property …which included information about and/or communications with as many as 10,000 or more of Pohl’s clients/prospective clients. Favre and Precision stole physical copies of certain of the information, stole Pohl’s computers, and misappropriated electronic data to which they had access through Precision’s work for Pohl.”) (emphasis added). 8 Motion, at Exhibit A, Question 2(a)(3) and 2(b)(3). 9 Motion, Exhibit A, at Question No. 4(3). 13 through improper means or was breaching a duty of confidentiality by disclosing it.” AssuredPartners of Or., LLC v. Reese, No. 6:22-cv-00673-MC, 2022 U.S. Dist. LEXIS 233618, at *7 (D. Or. 2022) (emphasis added). In other words, the jury must find the first person in the chain committed direct misappropriation — i.e. kacquired the information by improper means – before any of those indirectly misCappropriating can be found liable. See TEX. CIV. PRAC. & REM. CODE § 134A.002 (3)(B)(ii)(a) (requiring the person misusing the trade secret to know or have reaison know that the trade secret was “derived from or through a person who used improper means to acquire the trade secret”). Here, the jury answered “No” to the question of whether Precision had misappropriated Pohl’s trade secrets even tlhough Precision was defined in the charge to include Walker, Seymour and LadnMer prior to May 12, 2015 and Favre after May 12, 2015.10 The jury’s finding that Precision, and those associated with Precision, did not misappropriate anything —i meaning it either owed no duty to Pohl or breached no duty to Pohl when it provided Pohl's alleged information to Kassab — precludes liability against Kassaob for indirect misappropriation. a l PRAYER FOR RELIEF For all tihese reasons, Kassab objects to the judgment submitted by Pohl and respectfully requests that the Court refrain from signing the proposed judgment. 10 See Motion, at Exhibit A, p. 5. 14 ALEXANDER DUBOSE & JEFFERSON LLP /s/ Kevin Dubose Kevin Dubose kdubose@adjtlaw.com Texas State Bar No. 06150500 1844 Harvard Street k Houston, Texas 77008 e Phone (713) 523-0667 C Facsimile (713) 522-4553 FOGLER, BRAR, O’NEItL & GRAY, LLP /s/ Murray Fogler Murray Fogler mfogler@feoglerbrar.com Texas State Bar No. 07207300 909 Faunnin, Suite 1640 Houston, Texas 77002 (713) 481-1010 (l713) 574-3224 (Fax) THME KASSAB LAW FIRM /s/ David Eric Kassab e Lance Christopher Kassab i Texas State Bar No. 00794070 f David Eric Kassab Texas State Bar No. 24071351 1214 Elgin Street o Houston, Texas 77004 Telephone: (713) 522-7400 l E-service: eserve@kassab.law i ATTORNEYS FOR KASSAB DEFENDANTS CERTIFICATE OF SERVICE I certify that this document has been forwarded to all counsel pursuant to the Texas Rules of Civil Procedure on September 15th, 2023. /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 Bar No. 24071351 david@kassab.law r Envelope ID: 79605741 Filing Code Description: No Fee Documents Filing Description: t Status as of 9/15/2023 2:32 PM CST i Case Contacts D Name BarNumber Email e TimestampSubmitted Status Todd Taylor ttaylor@jandflaw.com 9/15/2023 1:38:22 PM SENT Jean C.Frizzell jfrizzell@reBynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Jean C.Frizzell jfrizzell@nreynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Harris Wells hwellsi l@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Todd Taylor ttaylor@jandflaw.com 9/15/2023 1:38:22 PM SENT Scott M.Favre scott@favrepa.com 9/15/2023 1:38:22 PM SENT Lawyer Wade lawyerwade@hotmail.com 9/15/2023 1:38:22 PM SENT Chris C.Pappas cpappas@krcl.com 9/15/2023 1:38:22 PM SENT Non-Party Witness Billy Shepherd O bshepherd@spcounsel.com 9/15/2023 1:38:22 PM SENT Non-Party Dona Pohl y DonaLyann@yahoo.com 9/15/2023 1:38:22 PM SENT Non-Party Edgar Jaimes o edgarsroom@gmail.com 9/15/2023 1:38:22 PM SENT Lance Kassab lance@kassab.law 9/15/2023 1:38:22 PM SENT David Kassab david@kassab.law 9/15/2023 1:38:22 PM SENT Nicholas Pierce f i nicholas@kassab.law 9/15/2023 1:38:22 PM SENT Lance Kassab eserve@kassab.law 9/15/2023 1:38:22 PM SENT Andrea Mendez andrea@kassab.law 9/15/2023 1:38:22 PM SENT Murray JFogler mfogler@foglerbrar.com 9/15/2023 1:38:22 PM SENT Murray Fogler mfogler@fbfog.com 9/15/2023 1:38:22 PM SENT Andrew Johnson ajohnson@thompsoncoe.com 9/15/2023 1:38:22 PM SENT Benjamin Ritz britz@thompsoncoe.com 9/15/2023 1:38:22 PM SENT Dale Jefferson 10607900 jefferson@mdjwlaw.com 9/15/2023 1:38:22 PM SENT Raul Herman Suazo 24003021 suazo@mdjwlaw.com 9/15/2023 1:38:22 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: 79605741 Filing Code Description: No Fee Documents Filing Description: t Status as of 9/15/2023 2:32 PM CST i Case Contacts D Kevin Graham Cain 24012371 cain@mdjwlaw.com 9/15/2023 1:38:22 PM SENT D Kassab david@kassab.law 9/15/2023 1:38:22 PM SENT Murray J. Fogler 7207300 mfogler@foBglerbrar.com 9/15/2023 1:38:22 PM SENT L Kassab lance@knassab.law 9/15/2023 1:38:22 PM SENT Murray J. Fogler 7207300 mfoglielr@foglerbrar.com 9/15/2023 1:38:22 PM SENT Thallia Malespin tmalespin@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Misty Davis mdavis@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Harris Wells hwells@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Kevin Dubose 6150500 kdubose@adjtlaw.com 9/15/2023 1:38:22 PM SENT Marisa Barrera Cruz Hurd 2O4041157 mhurd@adjtlaw.com 9/15/2023 1:38:22 PM SENT Kelly Skelton y reception@kassab.law 9/15/2023 1:38:22 PM SENT Harris Wells o hwells@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT Harris Wells hwells@reynoldsfrizzell.com 9/15/2023 1:38:22 PM SENT

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