fact_id,filing_id,fact 426,33,"Kassab anticipated litigation against Pohl no later than January 2015 — began circulating joint venture agreement by January 15, 2015" 427,33,"Joint venture agreement signed November 11, 2016: Kassab 50%, Montague 40%, Nicholson/Baker 10% fee split (50/25/25 if Baker leads)" 428,33,"Kassab's responsibilities: solicitation letters, client sign-up, draft petitions, bulk motion work, litigation, trial, front 50% of expenses" 429,33,Nicholson was brought in because she was licensed in many gulf states where lawsuits were contemplated 430,33,"Berry case filed June 5, 2017 (7 plaintiffs, auto accident/rollover solicitation), settled December 2019 with Pohl paying substantial sum" 431,33,"Cheatham case filed June 20, 2017 (4 plaintiffs, auto accident solicitation), initially dismissed, reversed on appeal August 30, 2022" 432,33,"Brumfield case filed June 8, 2017 (~62 plaintiffs, BP solicitation), dismissed on limitations, affirmed May 27, 2021, Supreme Court denied review Jan. 28, 2022" 433,33,"Gandy case filed October 16, 2017 (~135 plaintiffs, BP solicitation), dismissed on limitations" 434,33,"Kassab and Montague were previously co-counsel against John O'Quinn on behalf of 1,000+ silicosis clients (2011-2015)" 435,33,"Pohl filed this lawsuit August 28, 2018 while barratry litigation was still ongoing" 436,33,Precision Marketing alleged Pohl hired them to solicit clients in exchange for percentage of fees plus sum certain per referral 437,33,Precision Marketing acquired thousands of BP Deepwater Horizon clients and numerous auto accident cases for Pohl 438,33,"Representation contracts characterized claims as 'Barratry, Legal Malpractice and/or Breach of Fiduciary Duty' — not just barratry" 439,33,"Contingent fee structure in representation contracts: 33-1/3% pre-suit, 40% post-suit pre-trial, 45% post-trial"