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Key Assertions

1,237 material factual assertions from filings

Data license: Public court records

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assertion_id ▼ filing_id assertion
1 1 1 Pohl engaged Precision Marketing Group to provide public relations, evidence gathering, and client liaison services
2 1 1 While working for Pohl, Precision gained access to confidential information regarding up to 10,000 or more clients/prospective clients
3 1 1 The confidential information included client identities, contact information, attorney-client fee agreements, specialized legal forms, proprietary administrative forms, internal emails, and marketing information
4 1 1 Favre and Precision, with Nicholson's assistance, stole physical copies of information, stole Pohl's computers, and misappropriated electronic data
5 1 1 Favre secretly sold the stolen confidential information to Kassab and Montague for $250,000 in cash plus substantial bonuses
6 1 1 Kassab and Montague knew the information was stolen and not Favre's to sell
7 1 1 Kassab used the stolen information to solicit Pohl's clients to bring barratry and other cases against Pohl
8 1 1 A prior federal lawsuit (No. 1:14-cv-381-KS-JCG, Southern District of Mississippi) was resolved by a Confidential Settlement Agreement in late April/early May 2017
9 1 1 The Settlement Agreement required Favre and Precision to return all originals and copies of documents concerning Pohl's clients and to delete all electronically-stored information
10 1 1 Nicholson simultaneously served as counsel for Favre/Precision in the settlement and as co-counsel with Kassab/Montague in claims against Pohl
11 1 1 Favre and Precision breached the Settlement Agreement by failing to return documents, failing to delete ESI, and causing claims to be filed against Pohl
12 1 1 Kassab is described as a lawyer who specializes in suing other lawyers
13 1 1 Pohl seeks monetary relief in excess of $1,000,000.00
14 1 1 Pohl timely and fully performed the Settlement Agreement
15 1 1 All conditions precedent to Pohl maintaining this action have been performed or have occurred
16 2 2 Kassab filed four lawsuits on behalf of over 400 clients against Pohl in four different courts in Harris County alleging civil barratry and conspiracy to commit barratry
17 2 2 Pohl conspired with his wife Donalda Pohl, paralegal Edgar Jaimes, and three Mississippi runners (Walker, Seymour, Ladner) to illegally solicit clients
18 2 2 Donalda Pohl owns Helping Hands Financing, LLC ('HH Texas'), a sham lending company used to solicit accident victims; Jaimes runs its day-to-day operations
19 2 2 Walker, Seymour, and Ladner owned Precision Marketing Group, LLC and two other sham companies (Helping Hands Group, LLC and Helping Hands Financial, LLC)
20 2 2 For BP litigation, runners went door-to-door soliciting clients; Precision paid runners $300-$400 per client; Pohl paid Precision up to $1,500 per client
21 2 2 Pohl offered to pay Walker, Seymour, and Ladner a percentage of legal fees disguised as an hourly rate of $1,500 per hour
22 2 2 For auto accidents, Pohl used Google Alerts to identify crashes, then sent runners to hospitals, homes, and funerals to solicit victims
23 2 2 For auto accidents, Pohl paid runners as much as $7,500 per client and promised runners as much as 33% of Pohl's legal fees on the back end
24 2 2 HH Texas paid HH Mississippi $2,500 for every client referred to HH Texas as an additional layer between Pohl and runners
25 2 2 Runners used Helping Hands to offer money to victims conditioned on signing contracts allowing selection of Pohl as attorney
26 2 2 Pohl helped runners form the 'GM Settlement Verification Team' to impersonate a General Motors entity and solicit ignition-switch recall victims
27 2 2 Walker, Ladner, and Precision received over $5 million in 'barratry pass-through money' from Pohl and other lawyers
28 2 2 Walker testified the payments were 'clear to [him] it was barratry' and considered himself 'a pass-through for barratry money'
29 2 2 Magdalena Santana swore under oath that Pohl sent her on 'dozens and dozens of car wreck cases' and agreed to pay her $5,000 per case plus a percentage of fees
30 2 2 Pohl told Santana that minorities 'were especially vulnerable' and 'were easier to sign up'
31 2 2 Pohl paid Santana $50,000 in cash (delivered by Jaimes in bags marked 'trick or treat') to sign a gag agreement/retraction of her affidavit
32 2 2 Santana testified the first solicitation involved a case where a woman and her unborn child lost their lives; she was instructed to visit the funeral and told 'take no prisoners, this is a cut throat business'
33 2 2 Kenneth 'Coach' Talley solicited over 20 auto accident cases and more than 800 BP claims for Pohl
34 2 2 Talley carried blank Pohl contracts and up to $1,000 to pay accident victims, but only after they 'were signed up'
35 2 2 Talley was paid $1,400 plus expenses per auto accident case by Pohl through Walker, plus a portion of fees paid to Helping Hands
36 2 2 Talley testified both he and Pohl knew what they were doing was illegal; Talley was once 'run out of town' while soliciting
37 2 2 Walker was eventually indicted and sent to prison; Pohl then refused to pay runners promised fees
38 2 2 Pohl has judicially admitted that Kassab contacted Pohl's clients and filed suit against Pohl on behalf of these clients
39 2 2 Pohl admitted that a barratry claim is not a legal malpractice case and the discovery rule does not apply
40 2 2 Kassab has been assigned 150 barratry claims as of the filing date
41 2 2 Pohl's suit against Kassab is retaliatory, filed because Kassab represented Pohl's former clients and filed grievances
42 3 3 Pohl was introduced to Walker, Maxwell, Robinson, and Seymour in April 2012 and Ladner approximately six to eight weeks later, all holding themselves out as professional, experienced marketing consultants
43 3 3 PR Consultants represented they had their own Mississippi attorneys who reviewed and approved all contracts and confirmed services were lawful
44 3 3 The agreement provided for hourly fees, retainer, and expenses capped at 21% of LOMAP's 40% interest in the BP representation — not a percentage-of-fees payment
45 3 3 The percentage-of-attorney's-fees clause was a ceiling/cap on maximum amounts, not an independent promise to pay a percentage; this was orally discussed and understood by all parties before execution
46 3 3 Pohl never agreed to simply pay a percentage of attorney's fees to the PR Consultants
47 3 3 PR Consultants were solely responsible for hiring, paying, tax withholding, supervising, and issuing tax forms for all employees and contractors
48 3 3 In the Federal Court Lawsuit, PR Consultants themselves alleged hourly-rate payment basis and denied entitlement to any percentage of fees (Exhibit 1-A)
49 3 3 PR Consultants' services were substandard: improperly vetted claims, inadequately trained and supervised staff
50 3 3 PR Consultants were primarily supposed to run information booths at public events (boat shows, local festivals) and answer follow-up telephone calls
51 3 3 PR Consultants sent falsified and inflated invoices with 'PAID' stamps dated before preparation dates and systematically overcharged Pohl
52 3 3 PR Consultants charged up to $1,000/week in fictitious 'miscellaneous marketing' expenses from approximately March 2013 through September 2013
53 3 3 Walker admitted the 'miscellaneous marketing' characterizations were not truthful when confronted
54 3 3 PR Consultants secretly diverted hundreds of claimants to competing attorneys while being paid by Pohl for exclusive services
55 3 3 PR Consultants marketed their own services to competing attorneys offering reduced rates since Pohl was paying their overhead
56 3 3 The term 'barratry fees' was never used before Pohl's counterclaims in the Federal Court Lawsuit — it was concocted after PR Consultants were caught stealing
57 3 3 Nicholson and Favre both stated that PR Consultants admitted to stealing from Pohl (Exhibit 1-B)
58 3 3 Ladner admitted absconding with approximately 17 containers of client files from Pohl's office
59 3 3 PR Consultants and Nicholson refused to return four computers belonging to Pohl containing software, data, legal forms, trade secrets, and work product
60 3 3 Favre purchased the stolen materials despite being informed they were stolen; it appears Kassab eventually bought them from Favre
61 3 3 Julia Porter and Monica Chaney set up and operated a website using Pohl's name without authorization; Pohl sent cease and desist letters (Exhibits 1-D, 1-E)
62 3 3 Christopher Forrest appeared in May 2017 with a Pohl fee agreement — over three years after Pohl stopped accepting BP claims (Exhibit 1-F)
63 3 3 Pohl did not instruct PR Consultants to improperly solicit any persons and denies engaging in conspiracy to commit barratry
64 3 3 Pohl's fee arrangement with Williamson was a 60/40 split (60% Williamson, 40% Pohl) consistent with Texas law, with flexibility based on actual contribution
65 3 3 The $1,500/hour rate was considered excessive but accepted only because of the percentage cap
66 3 3 Pohl closed his Mississippi satellite office in February 2014
67 3 3 Precision Marketing Group succeeded Maxwell-Walker in January 2013
68 4 4 Montague Defendants had no attorney-client relationship with Pohl
69 4 4 Montague Defendants were not parties to the underlying Pohl litigation with Favre and Precision
70 4 4 Montague Defendants were not parties to or attorneys for parties to the Pohl settlement agreement
71 4 4 The referral of cases to specialists is a type of professional service that routinely and commonly falls within services an attorney would provide, thereby providing attorney immunity from liability
72 4 4 There is no basis to assert a claim of liability for conversion, theft of trade secrets, conspiracy, or otherwise against attorneys who are simply discharging traditional legal tasks
73 4 4 Plaintiffs' only link to Montague Defendants for each pled tort hinges on the bald assertion that they 'knew' confidential information had been stolen
74 4 4 Plaintiffs have no basis to allege Montague Defendants knew information was stolen
75 4 4 The referral of a possible case is not an unlawful act and cannot support tort claims against these Defendants
76 4 4 If defendant's liability for underlying tort is foreclosed as matter of law, there is no claim for conspiracy (citing Frankoff v. Norman)
77 4 4 Plaintiffs' own actions and decisions were not reasonable under the circumstances and charted the course for this dispute
78 5 5 Pohl testified under oath that Kassab, Nicholson, Montague, and others stole his files and robbed his Mississippi office
79 5 5 Pohl accused Kassab and co-counsel of hacking his computers and soliciting his clients with lies and material omissions to initiate suits against him
80 5 5 Pohl testified the crew's actions caused his clients 'to suffer damages in their own case and not get the money they were entitled to'
81 5 5 When pressed, Pohl clarified he did not personally witness who broke in — 'I wasn't there, and I didn't see who actually broke in and I didn't see who hacked my computer'
82 5 5 Pohl consistently referred to 'you, your co-counsel and your crew' rather than attributing acts to Kassab personally
83 5 5 Pohl alleged the theft occurred at his Gulfport, Mississippi office around 2014 and continued into 2015-2016 in connection with the closing of the office
84 5 5 Pohl alleged Favre paid Walker and Ladner $85,000 to rob his office based on 'private documents that I got'
85 5 5 Pohl alleged additional money was paid to hack his computers and sell passwords to Kassab or his co-counsel
86 5 5 Pohl admitted he filed no police report anywhere regarding the alleged office robbery and theft
87 5 5 Pohl admitted he had not filed a grievance with the State Bar against Kassab
88 5 5 Pohl admitted he had not contacted the Harris County DA about the alleged theft
89 5 5 Pohl admitted he had not contacted the Texas Attorney General about the alleged theft
90 5 5 Pohl explained the events 'didn't occur in Texas' so the Harris County DA 'would have nothing to do with it anyway'
91 5 5 Pohl's only law enforcement contact was speaking to a retired District Attorney in Oklahoma about 'the feasibility of filing charges'
92 5 5 Pohl explained his inaction by saying he 'prayed about it and hoped that a just result would ensue' and wanted to 'spend time to reflect on it before taking action' and not do anything 'precipitous'
93 5 5 Pohl stated the criminals were 'extorting money from me and they wanting millions of dollars for the return of my stolen goods'
94 5 5 When asked for evidence of password sale, Pohl admitted 'I haven't marshaled all the evidence'
95 5 5 Pohl identified the 'crew' as Kassab, Tina Nicholson, Doug Montague, June Allison, Kirk Ladner, Scott Walker, and Scott Favre
96 6 6 Pohl, Williamson, and Rusnak formed a joint venture and conspiracy to commit barratry in violation of Texas Penal Code § 38.12 and multiple disciplinary rules
97 6 6 The conspiracy illegally solicited approximately 9,800-10,000 prospective BP Deepwater Horizon clients along the Gulf Coast
98 6 6 Pohl, Williamson, and Rusnak agreed to split fees 40% (Pohl) / 60% (Williamson and Rusnak)
99 6 6 Beginning April 2012, Pohl hired Walker, Seymour, and later Ladner as runners to solicit clients
100 6 6 Dane Maxwell and CMV Investigations hired in early May 2012 to cold-call clients at $1,000 per client; paid up to $2.47 million

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CREATE TABLE key_assertions (
    assertion_id INTEGER PRIMARY KEY AUTOINCREMENT,
    filing_id INTEGER REFERENCES filings(filing_id),
    assertion TEXT
);
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