theory_id,filing_id,theory,party,role,basis
275,35,Statute of Limitations Defense (rebutted),Kassab/Nicholson,affirmative_defense,"Defendants argue claims are time-barred; Pohl shows conversion claim accrued no earlier than November 2016 (within 2-year period per § 16.003(a)), TUTSA claim accrued no earlier than November 10, 2016 (within 3-year period per § 16.010(a)), and each possession of converted property is a new conversion (Pemex)"
276,35,Attorney Immunity Defense (rebutted),Kassab/Nicholson,affirmative_defense,Defendants claim attorney immunity; Pohl responds that immunity applies only to lawyerly work in adversarial contexts (Taylor v. Tolbert) and conduct foreign to duties of lawyer is not protected (Haynes & Boone v. NFTD)