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Key Assertions

1,237 material factual assertions from filings

Data license: Public court records

16 rows where filing_id = 55

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assertion_id ▼ filing_id assertion
931 55 55 The Amended Motion does not specify what prior motions it purports to amend
932 55 55 Kassab does not explain why the prior rulings denying summary judgment were wrong
933 55 55 The vast majority of the Amended Motion is directly copied and pasted from Kassab's prior denied MSJs
934 55 55 Under 281st Court Procedure I(I), all motions to reconsider are heard by submission only
935 55 55 Kassab filed his January 4, 2023 Motion to Reconsider with the 189th District Court despite the case having been transferred
936 55 55 The Amended Motion contains only 5 new exhibits (out of 65 total) and 2 new out-of-state cases
937 55 55 Once Pohl provided sufficient evidence on each element in prior briefing (30+ exhibits), further no-evidence challenges on the same elements are futile
938 55 55 Kassab's sole new no-evidence argument — that Pohl must prove he is 'wholly innocent in the illegal obtainment of any client' — is not an element of any of Pohl's claims, unsupported by authority
939 55 55 Kassab selectively cites testimony that is contradicted by the same witnesses in the same depositions
940 55 55 Walker, Ladner, and Seymour testified both that information was theirs AND that it was Pohl's — creating disputed material facts
941 55 55 Mary Arnold testified she understood Pohl owned the relevant information and it was not to be shared or discussed around third parties
942 55 55 Pohl testified about reasonable steps to protect client information, confidential information, and trade secrets
943 55 55 Dugger v. Arredondo explicitly found the common law unlawful acts doctrine is 'no longer a viable defense'
944 55 55 Even if not preempted, Pohl does not need to rely on any illegal act to establish his claims — the illegal conduct arises in Kassab's defense, not Pohl's case
945 55 55 Alderson dealt with a False Claims Act / tax characterization issue — factually inapposite to customer list trade secret protection
946 55 55 No Texas case has adopted the Restatement (Third) of Unfair Competition § 40 privilege to disclose trade secrets cited in Merckle GmbH

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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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