fact_id,filing_id,fact
173,10,Shepherd's affidavit does not state it is based on personal knowledge or that facts are true and correct
174,10,Shepherd is not identified as custodian of records for any documents attached
175,10,Pohl's declaration fails to identify what the alleged trade secrets actually are
176,10,Pohl fails to explain how he maintained confidentiality given information freely ended up in Favre's hands
177,10,Favre claimed ownership of the marketing material provided to Kassab
178,10,Any documents Kassab obtained from Favre or Nicholson came into Favre's possession when he purchased Precision Marketing Group
179,10,"Under Texas law, the attorney is the agent of the client and work product belongs to the client"
180,10,"Everything in the entire client file belongs to the client — attorney notes, legal memoranda, etc."
181,10,Pohl does not allege that the Favre-Kassab agreement effectuated a sale of legal services
182,10,Pohl has not established that Kassab 'engaged in the conduct on which the claim is based in the defendant's capacity as a seller' of legal services
183,10,Kassab is not primarily engaged in purchasing marketing lists and client files