assertion_id,filing_id,assertion 659,37,David Kassab is Lance Kassab's nephew and law partner at The Kassab Law Firm 660,37,David Kassab was counsel in four barratry lawsuits collectively involving over 400 plaintiffs against Pohl 661,37,The Berry case included 7 plaintiffs allegedly solicited by Precision to hire Pohl for auto accident claims 662,37,The Cheatham case included 4 plaintiffs allegedly solicited by Precision to hire Pohl for auto accident claims 663,37,"The Brumfield case had approximately 272 plaintiffs by July 26, 2017 alleged to have been solicited for BP claims" 664,37,The Gandy case included approximately 135 plaintiffs alleged to have been solicited for BP claims 665,37,"In February 2018, Kassab's office received hundreds of client files from Pohl containing attorney-client contracts and communications" 666,37,Robert Ammons was Pohl's co-counsel in underlying auto accident cases and helped provide client files 667,37,"Billy Shepherd, Pohl's counsel, provided client files for Cheatham and Berry cases" 668,37,"Pohl produced approximately 6,937 pages from the Mississippi Litigation" 669,37,"Discovery requests cover April 2012 to January 2021 and require identifying every document bearing Pohl's name, letterhead, or logo" 670,37,Discovery defines 'Pohl Information' to include information concerning past/current/prospective clients and documents about BP Deepwater Horizon and GM ignition/rollovers 671,37,"It would take an estimated 405+ hours ($182,250 at $450/hour) to fully comply with Pohl's interrogatories" 672,37,There are more than 400 electronic or hardcopy client files for Brumfield and Gandy plaintiffs 673,37,"In the Cheatham case alone, more than 61,000 pages of documents were produced plus 6,000+ pages from Mississippi Litigation" 674,37,"Despite the burden, Kassab has produced more than 366,000 pages in twelve production sets from October 2021 through September 2022" 675,37,Included in the production are actual documents and information concerning Precision's clients that runners solicited to hire Pohl received from Favre 676,37,Staff had to filter hundreds of pages from hundreds of client files for privileged information including Kassab's communications with clients/co-counsel and attorney work product