theory_id,filing_id,theory,party,role,basis
151,16,"Statute of Limitations — Tex. Civ. Prac. & Rem. Code §§ 16.003, 16.010",Kassab,affirmative_defense,Pohl's conversion claim (2-year period) and TUTSA claim (3-year period) are time-barred because Pohl knew of the alleged misconduct in 2014 but did not file until August 2018; continuing misappropriation is a single cause of action under § 16.010(b)
152,16,Res Judicata / Claim Preclusion,Kassab,affirmative_defense,"Pohl's claims against Kassab arise from the same subject matter as the Federal Court Case, which resulted in a final judgment with prejudice on April 21, 2017. Kassab is in privity with Precision as an alleged co-conspirator. Pohl knew of Kassab's involvement during federal discovery but chose not to add Kassab as a party."
153,16,Attorney Immunity Doctrine,Kassab,affirmative_defense,An attorney is immune from liability to nonclients for conduct within the scope of client representation. Kassab's solicitation of clients and filing of barratry lawsuits is protected conduct even if characterized as wrongful or criminal. Applies to pre-litigation conduct. Highland Capital directly analogous.