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Legal Theories

509 claims, defenses, counterclaims, and affirmative defenses

Data license: Public court records

8 rows where filing_id = 22 and party = "Pohl"

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role 1

  • defense 8

party 1

  • Pohl · 8 ✖
theory_id ▼ filing_id theory party role basis
187 22 22 Res Judicata Pohl defense Prior final judgments on the merits in Brumfield and Gandy cases dismissed the same barratry claims; Kassab is in privity with Assignors as successor-in-interest; Kassab admits claims are the same; judgment final even if appealed; dismissal on limitations is on the merits
188 22 22 Statute of Limitations (four-year bar on barratry claims) Pohl defense Claims accrued when clients were solicited (no later than May 2013 for most; no later than 2014 for Clemons and Riggs), making them time-barred by May 2017 or 2016 respectively, before this lawsuit or the counterclaim was filed
189 22 22 Section 16.069 Inapplicability — Same Transaction or Occurrence Not Met Pohl defense The logical relationship test is not satisfied because facts of alleged barratry (2012-2014) are not significant and logically relevant to Pohl's conversion/trade secret claims regarding Kassab's 2016 conduct; separated by years, different parties, no common elements of proof
190 22 22 Section 16.069 Inapplicability — No Fair Notice Within 30 Days Pohl defense Kassab's counterclaim failed to identify the assignors or state facts giving rise to the claims, failing the Rule 47 fair notice requirement under Rogers; Pohl could not determine until discovery in 2021 that claims were identical to those rejected
191 22 22 Section 16.069 Inapplicability — Post-Lawsuit Assignment Cannot Revive Claims Pohl defense The statute's purpose of preventing tactical delay is not served when claims were assigned after litigation commenced; applying Code Construction Act factors (Ball), allowing this would frustrate the object, purpose, and public interest underlying § 16.069
192 22 22 Non-Assignability of Punitive Statutory Claims (PPG Industries framework) Pohl defense Civil barratry claims are personal and punitive statutory claims analogous to DTPA claims; the statute is silent on assignability; the legislature knew how to make them assignable but did not; purpose is to protect a specific class (clients); penalties are punitive in nature; assignments increase litigation
193 22 22 Public Policy Invalidity of Assignments Pohl defense Assignments that tend to increase or prolong litigation unnecessarily, serve as transparent devices to circumvent limitations, or injure the public good violate public policy and are void (Sw. Bell, LAKXN, Am. Homeowner, Wright v. Sydow, State Farm v. Gandy)
194 22 22 Violation of Ethical Rules — Tex. Disciplinary R. Prof'l Conduct 1.08(h) Pohl defense A lawyer shall not acquire a proprietary interest in the cause of action or subject matter of litigation the lawyer is conducting for a client; Kassab obtained assignments from his own clients concerning their pending litigation

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CREATE TABLE legal_theories (
    theory_id INTEGER PRIMARY KEY AUTOINCREMENT,
    filing_id INTEGER REFERENCES filings(filing_id),
    theory TEXT,
    party TEXT,
    role TEXT,
    basis TEXT
);
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