fact_id,filing_id,fact 831,66,"Filed January 19, 2024, simultaneously with JNOV Motion, within 30 days of Dec. 22, 2023 Final Judgment" 832,66,22 grounds for new trial enumerated 833,66,"December 8, 2023: Walker called Kassab and confessed to 30% promise, coached depositions, reversed testimony" 834,66,Walker and Ladner were co-owners of Precision Marketing Group 835,66,"Walker initially signed agreement that 17 boxes of materials were Precision's, not Pohl's" 836,66,"In Mississippi: Walker testified Pohl paid Precision $5M in barratry money, 'clear it was barratry'" 837,66,"In this case: Walker recanted, said Nicholson taught him about barratry, 'advised him to lie'" 838,66,"In recorded call: Walker confirmed 'it was barratry' and 'some of the things that we were doing was, in fact, barratry'" 839,66,Kassab did not call Walker/Ladner as live witnesses because of reversed deposition testimony 840,66,"Mary Francis Arnold (office manager) testified: contracts not trade secrets, not secured, Pohl never said they were trade secrets, kept in unlocked cabinets at home" 841,66,Client lists created by Jimmy Williamson and Precision; Pohl testified he did not have a list 842,66,Information kept unsecured in Ladner's garage; stored in Precision storage unit accessible to anyone 843,66,Master list on PACER for six years; produced in Mississippi discovery without protective order 844,66,Professor Benjamin Cooper: expert testimony that Pohl committed unauthorized practice of law excluded 845,66,Q2 improperly included direct misappropriation theory when only indirect misappropriation pled 846,66,Jury found Precision did NOT misappropriate but found Kassab 70% responsible — inconsistency 847,66,"Q5 jury answered August 19, 2017 but Pohl knew of Precision's theft in June 2014" 848,66,"Kassab's proposed questions 6, 7, and 8 all refused by Court" 849,66,Q6 'while in an attorney client relationship' language: improper comment on weight of evidence 850,66,Pohl stipulated in post-trial briefing he was not seeking equitable remedies 851,66,No evidence of Kassab's net worth presented to jury 852,66,"TUTSA caps exemplary at 2x actual loss — $500,000 max if attorney fees excluded" 853,66,"Billing invoices heavily redacted — impossible to determine tasks, timing, performers" 854,66,"Zavitsanos: Pohl's attorney fee expert, conclusory under Rohrmoos/Arthur Andersen factors" 855,66,"Zavitsanos not qualified on appellate fees, provided only conclusory lump sums" 856,66,No fee segregation between TUTSA claim (recoverable) and conversion claim (unrecoverable) 857,66,"Responsible third party designations denied: George W. Shepherd, Donalda Pohl, Edgar Jaimes, Ken Talley, Magdalena Santana" 858,66,Cheatham v. Pohl: pending civil barratry case; Pohl sought fees in this case for defending it 859,66,Pohl claimed privilege over Shepherd communications and unredacted billing records