fact_id,filing_id,fact 220,15,"Kassab's TCPA motion was denied by operation of law and appealed on December 18, 2018" 221,15,"Favre was served on September 14, 2018, making the 60-day TCPA deadline approximately November 13, 2018" 222,15,"Kassab filed his TCPA motion on October 24, 2018 (the 40th day), alerting co-defendants to the deadline" 223,15,"The court held a hearing on Kassab's TCPA motion on November 5, 2018" 224,15,Favre/Precision filed their TCPA motion three days after the 60-day deadline 225,15,"The Favre-Kassab Agreement dated November 10, 2016 required Kassab/Montague to pay $250,000 upfront non-refundable retainer" 226,15,The agreement contained indemnity and confidentiality provisions 227,15,"Favre confirmed under oath that $250,000 was paid and no work was performed between payment and April 2017" 228,15,"Favre testified he gave attorney/client fee contracts to Nicholson, not Kassab/Montague" 229,15,"Nicholson denied receiving fee contracts from Favre, creating contradictory testimony" 230,15,Favre maintained materials as confidential and protected them as valuable trade secrets 231,15,Settlement Agreement was executed in late April/early May 2017 232,15,"Pohl filed suit on August 28, 2018" 233,15,Pohl was not aware of the claims in the two-year period prior to filing