fact_id,filing_id,fact
374,28,"Pohl's First Amended Petition asserts four causes of action: breach of contract, conversion, TUTSA violations, and conspiracy"
375,28,Breach of contract is not subject to proportionate responsibility statute (Ch. 33 applies only to tort claims)
376,28,Conspiracy claim is entirely derivative of conversion and TUTSA claims
377,28,Pohl's conversion claim centers on allegations that Kassab and Montague 'knowingly purchased Pohl's stolen information/property'
378,28,"Pohl's TUTSA claim identifies two harms: (1) Favre/Precision/Nicholson's sale of trade secrets, (2) Kassab/Montague's use to bring lawsuits"
379,28,Kassab's discovery responses did not name Shepherd as a potential RTP
380,28,Kassab's discovery responses provided no addresses or telephone numbers for any alleged RTP
381,28,Pohl filed this lawsuit in 2018; 2-year conversion SOL and 3-year TUTSA SOL have both run
382,28,Pohl represented by Jean C. Frizzell of Reynolds Frizzell LLP