theory_id,filing_id,theory,party,role,basis 321,43,Specific Denial of Conditions Precedent,Kassab,defense,Kassab specifically denies that all conditions precedent regarding Pohl's conversion and trade secrets claims were performed or occurred prior to filing suit 324,43,Proportionate Responsibility / Responsible Third Parties,Kassab,defense,"Walker, Ladner, Seymour, Shepherd, Dona Pohl, Jaimes, Talley, and Santana caused or contributed to causing Pohl's alleged harm under Chapter 33, Tex. Civ. Prac. & Rem. Code ยง 33.011(6)"