theory_id,filing_id,theory,party,role,basis 257,33,Work Product Privilege,Kassab,defense,"Communications between Kassab, Montague, and Nicholson are work product because litigation against Pohl was anticipated no later than January 2015; they began discussing litigation in late 2014 and circulated a joint venture agreement by January 15, 2015" 258,33,Attorney-Client Privilege,Kassab,defense,Communications with barratry clients are privileged as attorney-client communications made for the purpose of facilitating the rendition of professional legal services in pursuit of barratry claims against Pohl 259,33,Confidentiality under Texas Disciplinary Rules of Professional Conduct,Kassab,defense,"Communications between co-counsel (Kassab, Montague, Nicholson) and with clients are confidential under the Texas Disciplinary Rules of Professional Conduct"