fact_id,filing_id,fact 860,67,"Filed February 2, 2024 in response to Kassab's January 19, 2024 motions" 861,67,Trial lasted nearly two weeks 862,67,Kassab has not filed proposed order as required by court procedures 863,67,Walker first tried to extort Pohl for share of judgment; Pohl refused; Walker then approached Kassab to sell testimony 864,67,Walker gave 2018 depositions consistent with 2022 testimony — no reversal 'in this case' 865,67,Kassab did not disclose Walker's extortion attempt or offer to sell testimony when requesting mistrial 866,67,Charge conference: Kassab stated 'Not to Number 2' when asked for Q2 objections — waiver 867,67,Kassab insisted on inclusion of wrongful conduct question (Q3) then objects it was untied — waiver 868,67,No attorney-client relationship existed when Kassab used trade secrets for mass solicitation of potential clients 869,67,Pohl's claims accrued no earlier than November 2016 when Kassab purchased information; suit filed less than 2 years later 870,67,Client information kept in locked office above bank with security; workers understood confidentiality 871,67,Kassab willing to pay over six figures for the information — inconsistent with public availability claim 872,67,Kassab only successfully obtained barratry clients after purchasing Pohl's trade secrets — prior public-information letters unsuccessful 873,67,Kassab involved in drumming up seven failed grievances against Pohl 874,67,"Kassab publicized unreviewed grievance to TX AG, Harris County DA, Houston Chronicle, Texas Lawyer, and Bar President candidate" 875,67,Kassab secretly purchased client files under guise of phony expert agreement; federal judge called it purchase agreement; Kassab lied to jury about nature 876,67,Kassab indemnified Favre against disclosure claims in the agreement 877,67,Pohl has never been found by any adjudicatory body to have committed barratry 878,67,Jury found over $2M actual damages; $3M exemplary complies with TUTSA 2x cap 879,67,Zavitsanos applied blanket 10% discount to fees for unnecessary/unrecoverable entries 880,67,Shepherd produced nearly half million pages at Kassab's request via subpoena 881,67,189th District Court denied Kassab's first responsible third party motion; Kassab re-filed same facts with cosmetic changes 882,67,Kassab concealed identity of who assigned barratry counterclaims to avoid disclosing duplicative assertion in separate lawsuit 883,67,Pohl's proportionate responsibility: could not have misappropriated his own trade secrets under § 33.011(4)