fact_id,filing_id,fact
884,68,"Filed February 2, 2024, simultaneously with response to JNOV and New Trial motions"
885,68,Jury unanimously answered Q17 'Yes' per unanimity instruction; then answered Q19 ($3M) predicated on unanimous Q17
886,68,Jury did not answer Q18
887,68,Kassab did not request jury be polled
888,68,Kassab did not object to alleged verdict conflict before jury was discharged — waiver
889,68,Presiding juror's failure to sign Q17 unanimity certificate was inadvertent per Pohl — jury's answers to Q17 and Q19 per unanimity instructions control
890,68,"Pohl's actual damages exceed $1,400,000, greatly exceeding $765,000 settlement credit"
891,68,TUTSA § 134A.004(a) expressly authorizes recovery of both actual loss AND unjust enrichment not taken into account in actual loss
892,68,"Market value ($250,000) compensated forward loss; development costs ($200,000) compensated past unjust enrichment — not duplicative"
893,68,Kassab secretly purchased files under phony expert agreement; lied about purchase despite federal judge's finding
894,68,"Kassab publicized dismissed grievance to TX AG, Harris County DA, Houston Chronicle, Texas Lawyer, and State Bar president candidate"
895,68,Kassab involved in drumming up multiple failed grievances and lawsuits against Pohl
896,68,Kassab's TUTSA expert Joseph Cleveland assumes conspiracy can coexist with TUTSA
897,68,Kassab's citation of Riner v. Neumann is false — case does not mention tort of another doctrine
898,68,Kassab's citation of Martin-Simon was overruled by Akin Gump on the relevant proposition
899,68,Q3 not tied to trade secrets — jury asked and Court (with Kassab's agreement) instructed to answer even without trade secret finding