assertion_id,filing_id,assertion
1,1,"Pohl engaged Precision Marketing Group to provide public relations, evidence gathering, and client liaison services"
2,1,"While working for Pohl, Precision gained access to confidential information regarding up to 10,000 or more clients/prospective clients"
3,1,"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,"Favre and Precision, with Nicholson's assistance, stole physical copies of information, stole Pohl's computers, and misappropriated electronic data"
5,1,"Favre secretly sold the stolen confidential information to Kassab and Montague for $250,000 in cash plus substantial bonuses"
6,1,Kassab and Montague knew the information was stolen and not Favre's to sell
7,1,Kassab used the stolen information to solicit Pohl's clients to bring barratry and other cases against Pohl
8,1,"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,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,Nicholson simultaneously served as counsel for Favre/Precision in the settlement and as co-counsel with Kassab/Montague in claims against Pohl
11,1,"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,Kassab is described as a lawyer who specializes in suing other lawyers
13,1,"Pohl seeks monetary relief in excess of $1,000,000.00"
14,1,Pohl timely and fully performed the Settlement Agreement
15,1,All conditions precedent to Pohl maintaining this action have been performed or have occurred