assertion_id,filing_id,assertion 677,38,"Kassab facilitated seven separate grievances and four lawsuits against Pohl, all based on barratry theory" 678,38,"Every grievance failed, often with findings that conduct did not constitute professional misconduct" 679,38,Two lawsuits resulted in final judgments on the merits in favor of Pohl 680,38,"In the third lawsuit, Pohl settled for less than the cost of defense — not the 'substantial sum of money' alleged by Kassab" 681,38,"The Cheatham appellate reversal was on limitations and extraterritoriality grounds, not because barratry was found" 682,38,"The Cheatham case involves only two sets of wrongful-death claimants out of 10,000+ of Pohl's clients whose information defendants misappropriated" 683,38,The outcome of the Cheatham case is not relevant to Pohl's claims; its relevance is only that defense fees are a component of actual damages 684,38,Kassab and David Kassab argued in Beatty v. Knighton that the unlawful acts doctrine was 'no longer good law' 685,38,The unlawful acts doctrine was preempted by Texas's proportionate responsibility statute (Dugger v. Arredondo) 686,38,"Even if the unlawful acts doctrine applied, Pohl's alleged barratry was not a proximate cause of the injuries from defendants' conversion and misappropriation" 687,38,Kassab's 'unclean hands' defense is inapplicable because it applies only to equitable relief and requires injury to the person raising the defense (In re Nolle) 688,38,Kassab does not explain how the outcome of Cheatham could have preclusive effect in this lawsuit involving different parties 689,38,Kassab does not explain what further factual development in Cheatham is necessary or impactful to issues in this case