section_id,filing_id,heading,summary
236,31,Rule 47 Statement,"Kassab seeks monetary relief of more than $1,000,000.00 as Counter-Plaintiff."
237,31,Parties,"Same party identifications as prior answers — Pohl (Colorado), Favre/Precision (Mississippi), Montague (Mississippi), Nicholson (Texas), Kassab (Texas)."
238,31,Jurisdiction and Venue,Jurisdiction and venue proper in Harris County.
239,31,General Denial,General denial of all Pohl's allegations; requires Pohl to carry burden of proof.
240,31,Affirmative Defenses,"Lists 23 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/unlawful acts rule, (14) First Amendment, (15) attorney immunity, (16) judicial immunity [NEW], (17) immunity under Rule 17.09 [NEW], (18) in pari delicto, (19) res judicata, (20) defect of parties, (21) abandonment, (22) subject of a valid contract, (23) TUTSA preemption under § 134A.007(a)."
241,31,Specific Denials,Specifically denies conditions precedent for Pohl's conversion and trade secret claims were satisfied.
242,31,Factual Background and Procedural History,"Substantively identical to prior answers (¶¶17-35) — same detailed recitation of barratry scheme, including BP solicitation, auto accident solicitation, GM Settlement Verification Team, Santana and Talley details, Mississippi Litigation, Kassab's lawsuits and grievances, Pohl's retaliatory filing."
243,31,Counterclaim for Civil Barratry,"Same counterclaim based on assigned claims from 242 claimants under § 16.069, timely as compulsory counterclaims."
244,31,Claim for Attorney's Fees,"Same: Defendants contend Plaintiffs' TUTSA claims made in bad faith, entitling Defendants to recover reasonable attorney's fees under § 134A.005."
245,31,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."