assertion_id,filing_id,assertion 824,50,Pohl hired runners who received over $5 million in 'barratry pass-through money' to illegally solicit clients 825,50,Walker testified it was 'clear to him it was barratry' and considered himself 'a pass-through for barratry money' 826,50,"Walker, Ladner, and Precision Marketing trained '40 or 50 people' on how to 'go out and solicit contracts'" 827,50,"Payments funneled through Helping Hands Financing LLC, owned by Pohl's wife Donalda and operated by her cousin Jaimes" 828,50,Magdalena Santana testified Pohl sent her on 'dozens and dozens of car wreck cases all over the country' 829,50,"Pohl offered Magdalena $5,000 per signed case plus a percentage of attorney's fees" 830,50,Pohl instructed Magdalena to target minorities because they 'tended not to know that the law prohibited barratry' 831,50,"Pohl instructed runners to approach victims in 'hospitals, funeral homes' and told Magdalena 'take no prisoners, this is a cut throat business'" 832,50,"Pohl paid Magdalena $50,000 cash via Jaimes to sign a gag agreement, delivered in bags marked 'trick or treat'" 833,50,Magdalena testified the gag agreement was for her to 'keep quiet and not charge Pohl with any wrongdoing' 834,50,Talley solicited over 800 BP cases and 20 auto accident cases for Pohl 835,50,"Talley was paid $75-$350 per BP client and $1,400 per auto accident case" 836,50,"Talley carried blank Pohl contracts and up to $1,000 cash to each solicitation" 837,50,"Mae Berry was offered $500 for her son's funeral in exchange for hiring Pohl, three days after the fatal accident" 838,50,"Arthur and Lisa Speck were offered $1,000 cash after their 18-year-old daughter's death" 839,50,The Bethleys signed blank contracts provided by Ladner in exchange for money 840,50,Bikumbu and his injured children were solicited in the hospital by the Santanas just days after the accident 841,50,Raymond Butts was solicited in the hospital; his family called security saying 'these people are here soliciting for an attorney' 842,50,"Cheatham family was paid $24,000 to sign with Pohl ($18,000 to Cheatham Sr. via Helping Hands check)" 843,50,Lacy Reese was solicited the day after she buried her husband; Ladner flew to 'nowhere Arkansas' within seven days 844,50,"Walker, Ladner, and Precision sued Pohl in Mississippi federal court (Oct. 2014) for breach of contract" 845,50,Pohl argued in Mississippi Litigation that agreements were illegal—he should be judicially estopped from arguing otherwise 846,50,"Mississippi federal court denied Pohl's motion to dismiss, finding illegality would only apply to Pohl as the attorney" 847,50,"Mississippi Litigation dismissed with prejudice April 24, 2017 after Pohl settled" 848,50,"Favre purchased Precision and voluntarily gave client information to Nicholson, Kassab, and Montague" 849,50,Pohl's counsel Billy Shepherd told Favre on three occasions he and Pohl 'did not care' what Favre did with the contact information 850,50,Kassab obtained State Bar-approved advertisement letters and sent them to Pohl's former solicitation victims 851,50,Over 400 clients signed representation contracts with Kassab to pursue barratry claims 852,50,Kassab filed four separate barratry lawsuits in Harris County plus grievances under Rule 8.03 853,50,"Pohl's claims accrued in summer 2014 but suit was not filed until August 2018, exceeding all limitations periods" 854,50,"Pohl testified he knew in summer 2014 that his trade secrets had been taken: 'Yes, I knew they were not being made available to me'" 855,50,Pohl testified Kassab and his 'crew' robbed his office and stole his clients' names in 2014 856,50,Pohl took no action to recover property or stop dissemination after discovering the alleged theft 857,50,"In May 2015, Nicholson refused to return documents to Pohl, confirming latest possible accrual date" 858,50,Pohl does not own client files as a matter of law — clients own their own files under Texas law 859,50,"Arnold testified 10,000-11,000 contracts were rejected and returned to PMG, thrown out, or shredded" 860,50,Arnold testified Pohl's alleged trade secrets were kept in an unsecured storage shed and at her personal residence 861,50,Arnold testified she did not believe any of the material was a trade secret 862,50,No confidentiality or non-disclosure agreements existed with any of the lawyers or entities that had access to the information 863,50,"PMG, Walker, Ladner, and Seymour created the client lists; they belonged to PMG, not Pohl" 864,50,"Pohl is not licensed in Mississippi, Louisiana, Alabama, or Florida but solicited clients in all four states" 865,50,Pohl's expert Zavitsanos is biased because he was an advocate for Pohl's co-defendant in the barratry cases and was previously sued by Kassab 866,50,"Pohl seeks as damages 'the costs and expenses of serial litigations and serial grievances' — '[a]ny fees, any expenses, hotel rooms, long-distance phone calls, copy costs'"