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Key Assertions

1,237 material factual assertions from filings

Data license: Public court records

25 rows where filing_id = 34

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assertion_id ▼ filing_id assertion
580 34 34 None of the four barratry suits have been adjudicated on the merits — the issue of whether Pohl committed barratry has never been decided
581 34 34 The Berry case settled with Pohl paying a substantial sum, suggesting the barratry claims had merit
582 34 34 The Cheatham court of appeals found evidence that Pohl and Ammons 'coordinated the barratry scheme' and that Pohl directly funded solicitation
583 34 34 Pohl provides no evidence — only lawyer arguments — in support of his traditional MSJ; 'motions and arguments of counsel are not evidence'
584 34 34 Pohl is unwilling to swear to any facts in an affidavit and not even willing to swear under oath that he did not commit barratry
585 34 34 Justification can be based on exercise of legal rights or good-faith claim to colorable right — motive is irrelevant when legal right is conclusively established
586 34 34 Kassab had a legal right to acquire evidence to support barratry claims without making himself liable (Taylor v. Tolbert)
587 34 34 Kassab had obligation to investigate potential claims against Pohl or risk sanctions under Rule 13
588 34 34 Kassab obtained Grievance Complaint against Pohl, justified by duty to report under Rule 8.03
589 34 34 Kassab understood the Precision Marketing information was owned by Precision, not Pohl
590 34 34 Favre testified Precision Marketing owned the client lists and files
591 34 34 Pohl's own pleadings request injunctive relief (First Amended Petition ¶ 45) and 'equitable' relief (¶ 50), contradicting his claim that he does not seek equitable remedies
592 34 34 TUTSA requires 'rightful, legal, or equitable title' to a trade secret — Pohl's illegal acquisition through barratry negates ownership
593 34 34 Pohl's own lawyers recently used the illegality defense in Duncan Litigation Investments to obtain summary judgment on a barratry-related claim
594 34 34 Pohl's lawyers also used illegality defense in the Mississippi Litigation against Precision Marketing's claims
595 34 34 Pohl's global no-evidence challenge is conclusory and fails to specify elements of each defense — it is defective under Timpte Industries v. Gish
596 34 34 Walker pled guilty to one count of federal program fraud and one count of conspiracy to commit federal program fraud for fraudulently diverting and misusing federal grants
597 34 34 Pohl knew Walker was a convicted felon yet never required confidentiality or non-disclosure agreements
598 34 34 Walker testified the client list and documents were Precision Marketing's 'work product'
599 34 34 Ladner testified 'client information' was owned by Precision Marketing
600 34 34 Pohl has unreasonably resisted Kassab's discovery requests relating to the illegality defense since May 2021
601 34 34 Kassab filed a prior MSJ on June 8, 2021 establishing limitations, res judicata, and attorney immunity
602 34 34 Kassab's August 29, 2022 MSJ established immunity under Rule 17.09, judicial proceedings privilege, attorney immunity, limitations, unlawful acts bar, and Precision Marketing ownership of trade secrets
603 34 34 Three expert reports (Hardwick, Cooper, Cleveland) establish that Pohl committed barratry
604 34 34 The Cheatham court found Walker's deposition testimony on the same allegations constituted 'some evidence' of Pohl's barratry scheme

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CREATE TABLE key_assertions (
    assertion_id INTEGER PRIMARY KEY AUTOINCREMENT,
    filing_id INTEGER REFERENCES filings(filing_id),
    assertion TEXT
);
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