assertion_id,filing_id,assertion 332,20,"Pohl conspired with his wife Dona, paralegal Edgar Jaimes, and three Mississippi runners (Walker, Seymour, Ladner) to illegally solicit clients through barratry" 333,20,"Walker, Seymour, and Ladner owned and operated sham companies including Helping Hands Group LLC, Helping Hands Financial LLC, and Precision Marketing Group LLC to conceal the illegal solicitation conspiracy" 334,20,"For BP litigation, runners were paid $300-$400 per potential client obtained through door-to-door solicitation" 335,20,"Pohl paid Precision up to $1,500 per client referred and promised runners a percentage of legal fees disguised as hourly rates of $1,500/hour" 336,20,"For auto accidents, Pohl paid as much as $7,500 per client signed up plus 33% of his legal fees on the back end" 337,20,"HH Texas paid HH Mississippi $2,500 for every client referred to HH Texas as an additional buffer" 338,20,"Pohl used Google Alerts to identify auto accidents and dispatched runners to hospitals, homes, and funerals to solicit victims" 339,20,Runners used Helping Hands entities as a front to approach vulnerable victims under false pretenses of providing financial assistance 340,20,"Magdalena Santana testified under oath that Pohl agreed to pay her $5,000 per case plus a percentage of attorney's fees for illegal solicitation" 341,20,Pohl told Santana that minorities 'were especially vulnerable since they tended not to know that the law prohibited barratry' and 'were easier to sign up' 342,20,"Pohl sent paralegal Jaimes to Florida with a suitcase containing $50,000 cash to pay Santana in exchange for signing a statement agreeing not to report Pohl's illegal activity" 343,20,"Santana testified the $50,000 was delivered by Jaimes in three bags marked 'trick or treat'" 344,20,"Santana's December 19, 2017 retraction affidavit never states her former testimony is untrue — only that she does not 'agree with' it" 345,20,Santana testified she was 'forced to sign' the retraction 'under duress' and Jaimes told her Pohl demanded she state she received only nominal consideration 346,20,Kenneth Talley solicited over 20 auto accident cases and more than 800 BP claims for Pohl 347,20,"Talley carried blank contracts and up to $1,000 cash to pay accident victims who agreed to sign with Pohl" 348,20,"Talley testified he followed a checklist: bring flowers (max $50), offer money, make sure HH Texas funding schedule filled out before releasing cash" 349,20,Talley and Pohl both knew what they were doing was illegal; Talley was once told by a 'lawyer or policeman' it was against the law 350,20,"Walker, Seymour, Ladner, and Precision received over $5 million in 'barratry pass-through money' from Pohl" 351,20,Walker was eventually indicted and sent to prison 352,20,More than 400 illegally solicited clients contacted the Kassab Law Firm to request representation against Pohl 353,20,Kassab was required to notify the Texas State Bar of Pohl's violations pursuant to Rule 8.03 354,20,Pohl filed this lawsuit as retaliation against Kassab for representing clients and filing grievances 355,20,Kassab did not steal anything from Pohl and did not purchase any stolen documents belonging to Pohl 356,20,"Pohl is not the owner of documents received from Precision, Favre, Nicholson, Montague or anyone else" 357,20,Kassab has been assigned barratry claims on behalf of 242 claimants 358,20,The counterclaims are timely because they were filed within 30 days of the date Kassab filed his original answer 359,20,Pohl judicially admitted that barratry is not legal malpractice and Discovery Rule does not apply to barratry claims 360,20,Billy Shepherd knew Favre had given documents to third parties including Kassab prior to negotiating settlement 361,20,Shepherd may have intentionally failed to protect Pohl's interest to secure future lucrative employment for himself 362,20,Walker testified he and Precision owned all assets/property and had legal right to transfer them to Favre 363,20,Michael A. Pohl is an individual lawyer residing in Colorado