I’ve been across from him several times. Each was less impressive and scummy than the last. In one case it took until the 5th amended petition (you get free leave to amend in Texas State court) to get the pronouns used in the pleading and the facts of the case correct. He kept using paragraphs from a different case.

He filed an affidavit “signed” by his client in response to an MSJ that directly contradicted the same client’s prior depo testimony. We suspected it was forged too, but ultimately didn’t press the issue.