assertion_id,filing_id,assertion
289,17,Kassab's motion recycles arguments and limited evidence from the TCPA motion and interlocutory appeal
290,17,Kassab filed his MSJ prior to responding to any discovery
291,17,Pohl's claims against Kassab accrued no earlier than November 2016 when Kassab purchased the stolen information
292,17,"The undisputed November 10, 2016 Agreement is the earliest possible accrual date for claims against Kassab"
293,17,"Kassab was still acquiring possession of stolen property in December 2016 per the December 7, 2016 email"
294,17,Each possession of converted property is a new conversion under Texas law
295,17,"Pohl's conversion claim accrued no earlier than December 1, 2016 — well within the two-year period"
296,17,Kassab's evidence about prior wrongdoing by Precision and others does not establish when claims against Kassab specifically accrued
297,17,Pohl's deposition testimony only shows knowledge of 'some wrongful conduct by some individuals' at an undefined point prior to May 2018
298,17,Pohl affirmatively testified he was not aware of the claims in this case in the two-year period prior to filing
299,17,Kassab was not a party to the Federal Court Case or the settlement agreement
300,17,Precision itself did not move for summary judgment on res judicata
301,17,"The Federal Counterclaim addressed conversion of 'funds' (improper billing), not theft of confidential information"
302,17,Kassab provides no Texas authority for conspiracy-privity theory — relies only on out-of-state cases
303,17,Pohl's June 2018 affidavit reflects post-Federal-Case knowledge and does not establish claims could have been brought in the Federal Court Case
304,17,Kassab's purchase of stolen property preceded any attorney-client relationship
305,17,Kassab's solicitation and advertising to obtain clients necessarily preceded the 'meeting of the minds' required for attorney-client relationship
306,17,Attorney immunity requires conduct within scope of client representation that is not foreign to duties of a lawyer
307,17,"The First Court of Appeals' commercial-transaction characterization addresses the scope of a commercial transaction, not the scope of Kassab's duties to a client"