theory_id,filing_id,theory,party,role,basis
232,28,Insufficiency of RTP Designation — Fair Notice Pleading Standard,Pohl,objection,Movant must satisfy notice pleading standard with allegations of duty breached and sufficient allegations of causation so parties can ascertain the nature and basic issues of the controversy (In re Cordish Co.)
233,28,Harm vs. Damages Distinction (Tex. Civ. Prac. & Rem. Code § 33.011(6)),Pohl,objection,"A potential RTP must be responsible for the harm (injury) underlying the pled cause of action, not merely plausibly connected with damages (In re Smith; City Nat'l Bank; DLA Piper v. Linegar)"
234,28,Failure to Timely Disclose RTPs (Tex. Civ. Prac. & Rem. Code § 33.004(d)),Pohl,objection,"When limitations have passed on claims against the alleged RTPs, movant cannot designate them if they failed to timely disclose their identities under Tex. R. Civ. P. 194.2(l) (In re Dawson)"
235,28,Separate Conversion — Each Wrongful Possession Doctrine,Pohl,objection,Each wrongful possession of converted property is a separate conversion; Walker/Seymour/Ladner's prior possession is distinct from Defendants' possession and does not make them responsible for Defendants' conversion (Pemex v. BASF)