assertion_id,filing_id,assertion 548,33,"Kassab has been licensed to practice law in Texas since 1995 and has handled approximately 2,300 legal malpractice cases, the vast majority on the plaintiff's side" 549,33,"Kassab's date of birth is March 12, 1961; business address 1214 Elgin Street, Houston, Texas 77004" 550,33,Kassab graduated law school with honors and was editor-in-chief of Law Review 551,33,"Kassab is licensed before the U.S. Supreme Court, Fifth Circuit, and U.S. District Courts for the Southern, Eastern, and Western Districts of Texas" 552,33,Kassab was formerly a Briefing Attorney for the First Judicial District Court of Appeals in Houston and a former intern for the Texas Supreme Court 553,33,"Kassab has handled cases across Texas and in California, Utah, Nevada, Oregon, Idaho, Arkansas, Colorado, Virginia, Alabama, Louisiana, Florida and Mississippi" 554,33,"Kassab is owner of Lance Christopher Kassab, PC d/b/a The Kassab Law Firm" 555,33,"Kassab and Montague were previously co-counsel in lawsuits against John O'Quinn on behalf of more than 1,000 of O'Quinn's former silicosis clients (filed 2011, litigated through 2015)" 556,33,Montague notified Kassab of the Mississippi Litigation in fall 2014 557,33,"The Mississippi Litigation was filed by Walker, Ladner, and Seymore (owners of Precision Marketing) alleging Pohl hired Precision Marketing to solicit clients in exchange for fees" 558,33,Precision Marketing acquired thousands of BP Deepwater Horizon clients and numerous auto accident cases for Pohl 559,33,Kassab obtained information from PACER about the Mississippi Litigation 560,33,"Kassab met with Scott Favre, who became owner of Precision Marketing through purchase agreements with prior owners" 561,33,Kassab concluded that solicited clients had potential civil barratry claims under Section 82.0651 of the Texas Government Code 562,33,"On November 11, 2016, Kassab entered a joint venture agreement with Montague and Nicholson to pursue barratry claims against Pohl" 563,33,"Joint venture fee split: 50% Kassab, 40% Montague, 10% Baker/Nicholson (50/25/25 if Baker leads)" 564,33,"Kassab agreed to send solicitation letters, sign up clients, draft petitions, do bulk of motion work, litigate and try cases, and front 50% of expenses" 565,33,Nicholson was brought in because she was licensed in many gulf states where lawsuits were contemplated 566,33,"Favre and Nicholson provided Kassab with Precision Marketing's files including names and addresses of Pohl's former clients, prior to Favre's settlement of the Mississippi Litigation with Pohl" 567,33,"Kassab understood the information belonged to Precision Marketing based on purchase agreements where Walker, Ladner, and Seymore certified ownership of all assets" 568,33,Kassab did not know the information was allegedly acquired from Pohl by improper means or misappropriated by anyone 569,33,Kassab sent advertisement letters approved by the Texas State Bar and bars of other states to people who may have been barratry victims 570,33,Literally hundreds of individuals responded indicating they had been personally solicited to hire Pohl in auto accident or BP claims 571,33,Over 400 individuals contracted with Kassab's firm and co-counsel beginning at least by February 2017 572,33,The Berry case was settled on December 2019 with Pohl paying a substantial sum of money 573,33,"The Cheatham case was initially dismissed on summary judgment but reversed on appeal August 30, 2022 — court found dismissal erroneous" 574,33,"The Brumfield and Gandy cases were dismissed on limitations; appellate court affirmed May 27, 2021; Texas Supreme Court denied review January 28, 2022" 575,33,"Pohl filed this lawsuit August 28, 2018 while barratry litigation was ongoing" 576,33,Kassab anticipated litigation against Pohl no later than January 2015 577,33,"Montague and Kassab started discussing litigation against Pohl in late 2014 and circulated a joint venture agreement by January 15, 2015" 578,33,"Representation contracts named claims as 'Barratry, Legal Malpractice and/or Breach of Fiduciary Duty' — broader than just barratry" 579,33,"Some contracts named defendants as 'Jimmy Williamson, Jimmy Williamson, P.C. and/or Michael A. Pohl' while others named only Michael A. Pohl"