assertion_id,filing_id,assertion
308,18,Pohl's entire Declaration consists of nothing but conclusory statements insufficient to raise fact issues
309,18,"Under Texas law, 'a client owns the contents of his or her file' — contradicting Pohl's ownership claims"
310,18,Pohl's use of 'purported to sell' and 'appears' language constitutes impermissible speculation
311,18,"Pohl was not a party to the November 10, 2016 Agreement or the December 7, 2016 email, and cannot authenticate them"
312,18,Pohl's paragraph 10 is internally contradictory regarding who was a party to the Federal Court Case
313,18,"With Paragraphs 5-10 and Exhibits 1-2 struck, Pohl has no evidence to defeat summary judgment"
314,18,"Pohl testified under oath that Kassab and his 'crew' broke into his office in Gulfport, Mississippi and stole his stuff in 2014"
315,18,"Pohl did not immediately file suit because he 'wanted to spend time to reflect on it before taking action' and 'didn't want to do anything that was precipitous' (Mot. Exhibit 3, at 93)"
316,18,Pohl does not dispute his deposition testimony in his Response
317,18,"Pohl never pled the discovery rule, so it does not apply"
318,18,"Even if the discovery rule applied, an office break-in is not inherently undiscoverable"
319,18,"The December 7, 2016 email is unauthenticated hearsay that does not mention Pohl by name"
320,18,Pohl testified under oath that he learned of the basis of his claims against Kassab during discovery in the Federal Court Case
321,18,"Pohl testified that Precision and Walker 'undertook to convert, misappropriate' his files and information (Mot. Exhibit 1, par. 28)"
322,18,Pohl testified information was in 'approximately seventeen clear plastic file containers' and Ladner admitted absconding with them
323,18,"Pohl judicially admitted that Favre, Precision, and Kassab are co-conspirators, establishing privity for res judicata"
324,18,Precision was owned by Favre during pendency and settlement of the Federal Court Case
325,18,The First Court of Appeals' characterization of Kassab's conduct as involving 'the type of legal services Kassab provides' is the law of the case
326,18,Pohl cannot escape the court of appeals opinion no matter how he characterizes the facts
327,18,Merely labeling an attorney's conduct 'fraudulent' does not remove it from the scope of client representation
328,18,Even criminal conduct is not categorically excepted from attorney civil immunity when connected with representing a client