defense_id,filing_id,defense 71,10,"Shepherd affidavit is defective — not based on personal knowledge, no perjury attachment, merely a statement by interested counsel" 72,10,"Shepherd affidavit fails to establish business records foundation — not shown as custodian, all six elements unmet" 73,10,All Shepherd exhibits are inadmissible hearsay upon hearsay 74,10,Shepherd failed to provide requisite notice of filing under Rule 902(10) 75,10,Pohl's declaration paragraphs 3-9 are conclusory and constitute no evidence as a matter of law 76,10,"Documents came from Precision Marketing Group, not Pohl — Precision owned the documents" 77,10,Client files belong to clients under Tex. Disciplinary R. Prof'l Conduct 1.15(d) — Pohl never owned the subject documents 78,10,Pohl lacks standing for conversion or trade secret claims 79,10,Commercial speech exception does not apply — Pohl failed to prove all four Castleman elements; party asserting exemption bears burden