theory_id,filing_id,theory,party,role,basis
56,7,Texas Citizens Participation Act (TCPA/Anti-SLAPP) — Right of Free Speech (Tex. Civ. Prac. & Rem. Code § 27.001(3)),Kassab,defense,Pohl's lawsuit targets communications made in connection with matters of public concern — barratry lawsuits and grievances discussing illegal attorney conduct; legal services constitute 'services in the marketplace'
57,7,TCPA — Right to Petition (Tex. Civ. Prac. & Rem. Code § 27.001(4)),Kassab,defense,Filing barratry lawsuits and State Bar grievances are communications made in or about judicial and governmental proceedings
58,7,TCPA — Right of Association (Tex. Civ. Prac. & Rem. Code § 27.001(2)),Kassab,defense,Kassab joined with his clients to collectively pursue their common interest in bringing barratry claims against Pohl
59,7,"Attorney Immunity Doctrine (Cantey Hanger, LLP v. Byrd)",Kassab,affirmative_defense,"All complained-of conduct — obtaining client information, filing lawsuits, filing grievances — falls within the scope of client representation; Highland Capital directly analogous"
60,7,"Statute of Limitations (Tex. Civ. Prac. & Rem. Code §§ 16.003, 16.010)",Kassab,affirmative_defense,"Pohl knew of his claims in 2014 (moved from Gulfport office, learned from secretary clients were diverted, Mississippi Litigation discovery began October 2014) but did not file until August 2018, exceeding the 2-year conversion/conspiracy and 3-year TUTSA limitations periods"
61,7,Res Judicata / Claims Preclusion,Kassab,affirmative_defense,"Pohl sued Precision Marketing for conversion, fraud, and unjust enrichment in the Mississippi Litigation based on the same transactions; settled with prejudice on April 21, 2017"
62,7,Failure to Establish Conversion — Lack of Ownership,Kassab,defense,"Precision Marketing, not Pohl, owned the client lists and marketing information according to Favre's testimony"
63,7,Failure to Establish TUTSA Claim — Not Trade Secrets,Kassab,defense,Client names and addresses are publicly known and not trade secrets; Kassab reasonably believed Precision Marketing owned the materials