section_id,filing_id,heading,summary
196,27,Rule 47 Statement,"Kassab seeks monetary relief of more than $1,000,000.00 in his capacity as Counter-Plaintiff."
197,27,Parties,"Identifies all parties including Pohl (Colorado resident), Favre and Precision (Mississippi), Montague (Mississippi), Nicholson (Texas), and Kassab (Texas). Kassab and his P.C. are both defendants and counter-plaintiffs."
198,27,Jurisdiction and Venue,Asserts jurisdiction and venue in Harris County based on defendants' residency and location of acts/omissions.
199,27,General Denial,Kassab generally denies all allegations and requires Pohl to carry burden of proof.
200,27,Affirmative Defenses,"Lists 20 affirmative defenses: (1) statute of limitations, (2) justification, (3) estoppel, (4) waiver, (5) ratification, (6) release, (7) unclean hands, (8) contribution, (9) failure to mitigate, (10) lack of standing, (11) accord and satisfaction, (12) assumption of the risk, (13) illegality/criminal acts, (14) First Amendment, (15) attorney immunity, (16) in pari delicto, (17) res judicata, (18) defect of parties, (19) abandonment, and (20) subject of a valid contract."
201,27,Specific Denials,Specifically denies that all conditions precedent regarding Pohl's claims of conversion and theft of trade secrets were performed or occurred prior to filing.
202,27,Factual Background and Procedural History,"Extensive 19-paragraph recitation (¶¶17-35) of Pohl's barratry scheme. Details include: Pohl conspired with wife Dona (owner of Helping Hands Financing LLC), paralegal Edgar Jaimes, and Mississippi runners Walker/Seymour/Ladner operating through sham companies (HH Mississippi, Precision). BP client solicitation involved door-to-door knocking paying runners $300-$400 per client, with Precision receiving $1,500 per client. Auto accident solicitation via Google Alerts paying runners up to $7,500 per client plus 33% of fees. The $1,500/hour rate was a disguise for percentage-based fee sharing. Pohl helped form the GM Settlement Verification Team as a sham GM entity. Santana sent on 'dozens and dozens' of cases, paid $5,000 per case plus percentage. Pohl paid Santana $50,000 cash in three bags marked 'trick or treat' via Jaimes to sign gag agreement. Talley solicited 800+ BP claims and 20+ auto accident cases, carried blank contracts and followed a checklist. Walker was indicted and sent to prison, leading runners to file Mississippi Litigation. Kassab filed four lawsuits for 400+ clients and grievances pursuant to Rule 8.03. Pohl filed this retaliatory suit alleging conversion and theft of trade secrets."
203,27,Counterclaim for Civil Barratry,"Asserts counterclaims for civil barratry based on express assignments of interest from 242 claimants, invoking Tex. Civ. Prac. & Rem. Code § 16.069 to bring otherwise time-barred claims as compulsory counterclaims. Notes Pohl's own judicial admissions that barratry claims are not legal malpractice claims and the Discovery Rule does not apply, supporting assignability."
204,27,Prayer for Relief,"Seeks that Pohl recover nothing, and that Kassab recover (i) actual and consequential damages, (ii) statutory damages, (iii) pre- and post-judgment interest, (iv) attorneys' fees and costs, and (v) all other just relief."