assertion_id,filing_id,assertion 631,36,"The Court denied Kassab's original summary judgment motion on limitations, res judicata, and attorney immunity on August 3, 2021" 632,36,Scott Walker testified Nicholson prepared him for deposition and told him 'buzz words to say' including 'barratry' and 'cold calling' — words he'd never heard before 633,36,Walker testified he 'listened and did what my attorney said to do' regarding lying in depositions 634,36,Magdalena Santana wrote a letter to Judge Starrett stating she was coerced into signing the first affidavit prepared by Nicholson 635,36,"Santana's audio recording with Kassab confirms pressure from Nicholson and Favre — they called her mother's house, threatened her brother" 636,36,Santana rejected Kassab's suggestion that Pohl and Williamson set up a barratry scheme: 'The marketing firm is the one that hired me' 637,36,"The $50,000 payment to Santana was consideration under a May 21, 2014 release agreement, predating both affidavits" 638,36,"Kassab submitted over 60 pages of argument and 2,300 pages of exhibits for his individual grievance, but Pohl was cleared of wrongdoing" 639,36,All seven grievances filed against Pohl were dismissed by the State Bar and Board of Disciplinary Appeals 640,36,Kassab relies on eight inadmissible deposition transcripts from prior lawsuits cited over 100 times 641,36,Kassab's evidence authentication fails to satisfy business records requirements under Tex. R. Evid. 902(10) 642,36,Nicholson violated the Settlement Agreement by fomenting litigation against Pohl and failing to return materials 643,36,Settlement Agreement Paragraph 27 prohibits Claimants and Affiliates from filing any complaint or legal action against Pohl 644,36,Nicholson has not attached or verified the Settlement Agreement itself — no admissible evidence of release terms 645,36,Pohl's claims accrued when defendants purchased his stolen property in November-December 2016 646,36,Kassab and David Kassab argued in Beatty v. Knighton that the unlawful acts doctrine was 'no longer good law' 647,36,Precision represented to Pohl that it operated under guidance of experienced Mississippi attorneys and would ensure compliance 648,36,"Precision's misconduct: referred clients to other lawyers, fabricated expenses, overcharged, failed to keep time records" 649,36,"Nicholson raised barratry issue, provided Precision witnesses scripts, and threatened witnesses" 650,36,"Mississippi Magistrate Judge Gargiulo issued Oct. 14, 2016 and March 22, 2017 protective orders requiring strict confidentiality" 651,36,"Walker admitted he knew attorney-client contracts, computers, and client lists belonged to Pohl" 652,36,Ladner conceded materials were all 'Pohl's stuff' despite Nicholson telling him otherwise 653,36,Walker and Ladner testified hearing Favre and Nicholson discuss Pohl's files being worth $6 million 654,36,Favre confirmed Pohl's information was one of Precision's 'most valuable asset' 655,36,TUTSA damages include attorneys' fees incurred defending barratry litigation as 'actual loss caused by misappropriation' 656,36,"Pohl's contracts are voidable under barratry statute, not void — none have been declared void" 657,36,Purchasing stolen property before having any client is not 'uniquely lawyerly' work protected by attorney immunity 658,36,Soliciting clients to obtain attorney-client relationship necessarily precedes the relationship — no immunity for pre-relationship conduct