assertion_id,filing_id,assertion 16,2,Kassab filed four lawsuits on behalf of over 400 clients against Pohl in four different courts in Harris County alleging civil barratry and conspiracy to commit barratry 17,2,"Pohl conspired with his wife Donalda Pohl, paralegal Edgar Jaimes, and three Mississippi runners (Walker, Seymour, Ladner) to illegally solicit clients" 18,2,"Donalda Pohl owns Helping Hands Financing, LLC ('HH Texas'), a sham lending company used to solicit accident victims; Jaimes runs its day-to-day operations" 19,2,"Walker, Seymour, and Ladner owned Precision Marketing Group, LLC and two other sham companies (Helping Hands Group, LLC and Helping Hands Financial, LLC)" 20,2,"For BP litigation, runners went door-to-door soliciting clients; Precision paid runners $300-$400 per client; Pohl paid Precision up to $1,500 per client" 21,2,"Pohl offered to pay Walker, Seymour, and Ladner a percentage of legal fees disguised as an hourly rate of $1,500 per hour" 22,2,"For auto accidents, Pohl used Google Alerts to identify crashes, then sent runners to hospitals, homes, and funerals to solicit victims" 23,2,"For auto accidents, Pohl paid runners as much as $7,500 per client and promised runners as much as 33% of Pohl's legal fees on the back end" 24,2,"HH Texas paid HH Mississippi $2,500 for every client referred to HH Texas as an additional layer between Pohl and runners" 25,2,Runners used Helping Hands to offer money to victims conditioned on signing contracts allowing selection of Pohl as attorney 26,2,Pohl helped runners form the 'GM Settlement Verification Team' to impersonate a General Motors entity and solicit ignition-switch recall victims 27,2,"Walker, Ladner, and Precision received over $5 million in 'barratry pass-through money' from Pohl and other lawyers" 28,2,Walker testified the payments were 'clear to [him] it was barratry' and considered himself 'a pass-through for barratry money' 29,2,"Magdalena Santana swore under oath that Pohl sent her on 'dozens and dozens of car wreck cases' and agreed to pay her $5,000 per case plus a percentage of fees" 30,2,Pohl told Santana that minorities 'were especially vulnerable' and 'were easier to sign up' 31,2,"Pohl paid Santana $50,000 in cash (delivered by Jaimes in bags marked 'trick or treat') to sign a gag agreement/retraction of her affidavit" 32,2,"Santana testified the first solicitation involved a case where a woman and her unborn child lost their lives; she was instructed to visit the funeral and told 'take no prisoners, this is a cut throat business'" 33,2,Kenneth 'Coach' Talley solicited over 20 auto accident cases and more than 800 BP claims for Pohl 34,2,"Talley carried blank Pohl contracts and up to $1,000 to pay accident victims, but only after they 'were signed up'" 35,2,"Talley was paid $1,400 plus expenses per auto accident case by Pohl through Walker, plus a portion of fees paid to Helping Hands" 36,2,Talley testified both he and Pohl knew what they were doing was illegal; Talley was once 'run out of town' while soliciting 37,2,Walker was eventually indicted and sent to prison; Pohl then refused to pay runners promised fees 38,2,Pohl has judicially admitted that Kassab contacted Pohl's clients and filed suit against Pohl on behalf of these clients 39,2,Pohl admitted that a barratry claim is not a legal malpractice case and the discovery rule does not apply 40,2,Kassab has been assigned 150 barratry claims as of the filing date 41,2,"Pohl's suit against Kassab is retaliatory, filed because Kassab represented Pohl's former clients and filed grievances"