theory_id,filing_id,theory,party,role,basis
389,55,Motion to reconsider under 281st Court Procedure I(I),Pohl,opposition,The Amended Motion is substantively a motion to reconsider because it seeks the same relief with the same arguments as the denied MSJs; such motions must be heard by submission only under court procedures.
390,55,No-evidence summary judgment — futility of repeated challenges after evidence showing,Pohl,opposition,"Once a party has presented sufficient evidence to defeat a no-evidence motion, further no-evidence challenges on the same elements are futile. Pohl's prior 30+ exhibits addressed every element."
391,55,Preemption of unlawful acts doctrine by proportionate responsibility statute (Dugger v. Arredondo),Pohl,opposition,"The Texas Supreme Court explicitly found the common law unlawful acts doctrine is 'no longer a viable defense,' preempted by the proportionate responsibility statute."
392,55,Trade secret protection — reasonable measures to maintain secrecy (disputed facts),Pohl,opposition,Pohl testified about reasonable steps taken. Same witnesses Kassab relies on also testified Pohl limited access and ensured confidentiality. Disputed material facts preclude summary judgment.
393,55,Ownership of trade secrets — disputed facts preclude summary judgment,Pohl,opposition,"Walker, Ladner, and Seymour gave conflicting testimony on whether information belonged to them or Pohl. Disputed material facts preclude summary judgment."
394,55,Unlawful acts doctrine inapplicable when claims don't require reliance on illegal acts,Pohl,opposition,"When the illegal conduct arises in a defense and not in the plaintiff's case, the unlawful acts rule will not bar a plaintiff's claims (Carcamo-Lopez). Pohl's claims don't require reference to any illegal act."