assertion_id,filing_id,assertion
605,35,"Defendants purchased Pohl's stolen confidential information and property from Favre for $250,000 plus bonuses through a contract dated November 10, 2016"
606,35,Defendants took possession of Pohl's information no earlier than November 2016 and mostly beginning December 2016
607,35,"Defendants brought barratry claims on behalf of more than 400 plaintiffs, and claims of all but four have been finally resolved in Pohl's favor"
608,35,"All grievances filed by Kassab with the Texas State Bar have been rejected, many with findings that 'the conduct you described in the grievance does not violate the Texas Disciplinary Rules of Professional Conduct'"
609,35,"Kassab, Nicholson, and Montague entered into a co-counsel agreement to bring barratry claims against Pohl; Kassab testified agreement was in writing but not yet produced"
610,35,Montague admitted sending the information and materials that form the basis of Pohl's claims to Kassab in Texas
611,35,"Montague defined the documents as including 'attorney-client contracts, communications, and lists of clients'"
612,35,"Nicholson had an active role in ensuring the team received all client contracts (Nov. 22, 2016 email)"
613,35,Kassab and Montague were not satisfied with receiving Pohl's engagement agreements and wanted contact information for Pohl's clients to solicit barratry claims
614,35,"Walker, Ladner, and Seymour all testified that the client contracts and/or client lists belong to Pohl"
615,35,Pohl's client lists were valued by defendants because they belonged to Pohl and could be used to convince clients to bring barratry claims
616,35,Walker testified he heard Pohl's client list was worth $6 million; Ladner recalled being told boxes containing Pohl's information were worth $6 million
617,35,Favre paid $1.5 million to acquire Precision Marketing and files in its possession
618,35,"Defendants paid $250,000 plus bonuses for access to the materials"
619,35,"Pohl maintained his office at the top of Hancock Bank — 'the most secure location on the Coast' — with 24-hour security, coded elevators, security cameras, and files kept under lock and key"
620,35,Pohl testified he emphasized confidentiality to Precision and its employees 'numerous times throughout the relationship'
621,35,The agreement Kassab signed contains an indemnity provision where Kassab agreed to indemnify Favre for claims relating to disclosure of client information where asserted by Pohl
622,35,Nicholson sent threatening letters to get Walker and others to turn over Pohl's information
623,35,"Certain defendants' uses of trade secrets occurred after May 1, 2017, the date of the Settlement Agreement, in direct violation of that agreement"
624,35,Pohl's counsel Billy Shepherd made multiple demands to Nicholson for return of property
625,35,"Pohl sought sanctions from a federal court for failure to return his property (hearing Oct. 25, 2017)"
626,35,Kassab admitted attaching Pohl's fee agreements to solicitation letters sent to Pohl's clients
627,35,No Pohl client contracts have been declared void under the barratry statute
628,35,"Pohl's conversion claim accrued no earlier than November 2016, well within the two-year limitations period"
629,35,"Pohl's TUTSA claim accrued no earlier than November 10, 2016, well within the three-year limitations period"
630,35,Favre's participation in the conspiracy violated terms of the confidential Settlement Agreement resolving the Mississippi federal court lawsuit