assertion_id,filing_id,assertion 791,48,Pohl hired runners who received over $5 million in 'barratry pass-through money' to illegally solicit clients 792,48,Walker testified it was 'clear to him it was barratry' and considered himself 'a pass-through for barratry money' 793,48,"Walker, Ladner, and Precision trained '40 or 50 people' to 'go out and solicit contracts'" 794,48,"Helping Hands Financing owned by Pohl's wife Donalda, operated by cousin Edgar Jaimes" 795,48,Santana attempted to solicit 'forty to fifty' auto accident cases in multiple states; 15-18 were signed 796,48,Pohl instructed Santana to target minorities because they are 'unrecognized to the law' and 'easier to sign up' 797,48,"Pohl paid Santana $50,000 cash in 'trick or treat' bags to sign gag agreement" 798,48,"Talley solicited over 800 BP claims and 20+ auto accident cases, carried blank contracts and $1,000 cash" 799,48,Pohl testified under oath he knew trade secrets were taken in summer 2014 800,48,"Pohl testified Kassab and his 'crew' 'robbed my office, stole my clients' names' in 2014" 801,48,Pohl closed Gulfport Mississippi office in summer 2014; sent mover who found office empty 802,48,"Pohl did not file suit until August 28, 2018 — over 4 years after admitted discovery of theft" 803,48,Pohl testified he waited because he 'wanted to spend time to reflect on it before taking action' 804,48,"Pohl took no action to recover property, seek injunctive relief, or enter protective orders after discovering theft" 805,48,"As a matter of Texas law, clients own their own files — attorney does not own client files" 806,48,Favre testified Precision's marketing lists were 'solely the work product and property of Precision' 807,48,"Pohl committed unauthorized practice of law in Mississippi, Louisiana, Alabama, and Florida" 808,48,Pohl never licensed in Mississippi yet operated a 'satellite law office' there in 2012-2014 809,48,Taylor v. Tolbert (2022) is new Texas Supreme Court authority requiring reconsideration of attorney immunity 810,48,Court of appeals in this case characterized Kassab's conduct as arising from 'commercial transaction involving the type of legal services Kassab provides' (612 S.W.3d at 578) 811,48,Expert witness Zavitsanos is biased — was advocate for Pohl's co-defendant in barratry cases and previously sued by Kassab 812,48,Kassab's damages theory: Pohl seeks as damages 'costs and expenses of serial litigations and serial grievances' — which are predicated on protected activity