section_id,filing_id,heading,summary
212,29,Rule 47 Statement,"Kassab seeks monetary relief of more than $1,000,000.00 as Counter-Plaintiff."
213,29,Parties,"Same party identifications as Fifth Amended Answer — Pohl (Colorado), Favre/Precision (Mississippi), Montague (Mississippi), Nicholson (Texas), Kassab (Texas). Kassab and P.C. are both defendants and counter-plaintiffs."
214,29,Jurisdiction and Venue,Jurisdiction and venue proper in Harris County based on defendants' residency and location of acts/omissions.
215,29,General Denial,General denial of all Pohl's allegations; requires Pohl to carry burden of proof.
216,29,Affirmative Defenses,"Now lists 21 defenses — same 20 as Fifth Amended Answer plus new #21: Preemption pursuant to Tex. Civ. Prac. & Rem. Code § 134A.007(a), which provides TUTSA displaces conflicting tort claims based on trade secret misappropriation."
217,29,Specific Denials,Specifically denies conditions precedent for Pohl's conversion and trade secret claims were satisfied prior to filing.
218,29,Factual Background and Procedural History,"Substantively identical to Fifth Amended Answer (¶¶17-35) — same detailed recitation of barratry scheme including BP solicitation, auto accident solicitation via Google Alerts, GM Settlement Verification Team sham, Santana's affidavit and gag agreement, Talley's solicitation, Walker's indictment, Mississippi Litigation, Kassab's four lawsuits and grievances, and Pohl's retaliatory filing."
219,29,Counterclaim for Civil Barratry,"Same counterclaim based on assigned claims from 242 claimants under § 16.069, timely as compulsory counterclaims filed within 30 days of original answer."
220,29,Claim for Attorney's Fees (NEW),"New section (¶38): Defendants contend that all or some of Plaintiffs' claims for misappropriation under TUTSA were made in bad faith, entitling Defendants to recover reasonable attorney's fees under Tex. Civ. Prac. & Rem. Code § 134A.005."
221,29,Prayer for Relief,"Seeks that Pohl recover nothing; 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."