assertion_id,filing_id,assertion 227,13,Pohl's claims were filed far beyond the statute of limitations 228,13,There is a plethora of evidence establishing each essential element of the statute of limitations defense 229,13,"Pohl's lawsuit is retaliatory, filed in response to Kassab representing more than 400 clients against Pohl in four separate lawsuits" 230,13,Pohl is a seasoned lawyer and his counsel Jean Frizzell holds himself out as a 'Top 100 Super Lawyer' 231,13,It is unfathomable that Pohl and Frizzell could be so incompetent as to not know the claims were dead on arrival when filed 232,13,The only plausible explanation for filing frivolous claims was retaliation against Kassab 233,13,"The Court should sanction Pohl and Frizzell a minimum of $50,000 to deter future similar actions" 234,13,"Failure to sanction would reinforce lawyers to continue to harass, create delay, increase cost of litigation, and create conflicts with impunity"