defense_id,filing_id,defense
238,34,Justification — Kassab had legal right to investigate and pursue barratry claims; motive irrelevant when legal right established
239,34,"Unclean hands — Pohl seeks equitable relief (injunction, TUTSA equitable title, equitable prayer) despite own illegal conduct"
240,34,Illegality — Pohl's claims barred because trade secrets obtained through illegal barratry; same defense Pohl's lawyers used in Duncan Litig. Invs.
241,34,Unlawful Acts Rule — Pohl's illegal acts at time of injury bar recovery (Andrew Shebay v. Bishop)
242,34,Criminal Acts — Pohl's barratry is a criminal offense barring recovery
243,34,In Pari Delicto — Courts can deny recovery to Pohl for his own illegal acts even if defendants also acted wrongfully
244,34,Assumption of the Risk — Pohl trusted convicted felon Walker with trade secrets without NDA or confidentiality agreements
245,34,Lack of Standing / Defect of Parties — Pohl does not own the alleged trade secrets; Precision Marketing owns them per Walker and Ladner testimony
246,34,Attorney Immunity — established in prior MSJs including Rule 17.09 immunity and judicial proceedings privilege
247,34,Limitations — established in June 2021 and August 2022 MSJs
248,34,Res Judicata — established in June 2021 MSJ
249,34,Procedural defense — Pohl's no-evidence motion is conclusory and insufficient under Timpte Industries v. Gish