statute_id,filing_id,statute,description,cited_by 12,2,Tex. Civ. Prac. & Rem. Code § 16.069,"Permits filing of counterclaims and cross-claims arising from the same transaction or occurrence even if independently barred by limitations, if filed within 30 days of the answer deadline. Quoted in full in the filing.",Kassab 13,2,Texas Penal Code (barratry — third-degree felony),Referenced as the criminal barratry statute making illegal solicitation a third-degree felony; specific section number not cited in text,Kassab 14,2,Texas Disciplinary Rules of Professional Conduct Rule 8.03,Requires lawyers to report known violations of disciplinary rules; cited as basis for Kassab filing grievances against Pohl,Kassab 26,6,Tex. Penal Code § 38.12(a)(4),Criminalizes paying or offering to pay a person money or anything of value to solicit employment with intent to obtain economic benefit — third-degree felony,Kassab 27,6,"Tex. Penal Code § 38.12(b)(1), (2), (3)","Criminalizes financing barratry, investing funds to further barratry, and knowingly accepting employment resulting from barratrous solicitation",Kassab 28,6,Tex. Penal Code § 38.12(d)(2)(A),Criminalizes providing or permitting solicitation of accident/disaster victims within 30 days of the accident by a person with intent to obtain professional employment,Kassab 29,6,Tex. Penal Code § 32.43(b),"Commercial bribery: prohibits a fiduciary from soliciting, accepting, or agreeing to accept any benefit on understanding it will influence conduct in relation to beneficiary's affairs",Kassab 30,6,Tex. Penal Code Chapter 36,"Obstruction and witness tampering — cited in connection with Pohl paying Santana $50,000 to suppress testimony",Kassab 31,6,Tex. Gov't Code § 82.065,"Allows client to void contingent fee contract procured through barratry (enacted 1989, amended 2011 and 2013)",Kassab 32,6,Tex. Gov't Code § 82.0651,"Civil Liability for Prohibited Barratry — creates civil cause of action for persons solicited by barratrous conduct; provides $10,000 penalty, actual damages, and attorney's fees; to be 'liberally construed' (enacted 2011 by S.B. 1716, amended 2013 by H.B. 1711)",Kassab 33,6,Tex. Disciplinary R. Prof'l Conduct 1.03,Duty to keep client informed — Pohl failed to disclose material information about barratry to clients Cheatham and Reese,Kassab 34,6,"Tex. Disciplinary R. Prof'l Conduct 1.04(f)(1), (f)(2), (g)","Requirements for division of fees between lawyers not in same firm: proportionality or joint responsibility; written client consent identifying all lawyers, fee basis, and shares",Kassab 35,6,Tex. Disciplinary R. Prof'l Conduct 1.15(a)(1),Mandatory withdrawal when representation will result in rule violation,Kassab 36,6,Tex. Disciplinary R. Prof'l Conduct 3.04,"Fairness in adjudicatory proceedings — violated by paying Santana $50,000 to suppress testimony",Kassab 37,6,Tex. Disciplinary R. Prof'l Conduct 4.02,Prohibition on communicating with represented persons — Pohl approached Kassab's client during deposition,Kassab 38,6,"Tex. Disciplinary R. Prof'l Conduct 5.04(a), (d)(1)",Prohibition on sharing or promising to share legal fees with a non-lawyer,Kassab 39,6,Tex. Disciplinary R. Prof'l Conduct 5.05,Unauthorized practice of law — Pohl operated offices in Mississippi and Tennessee without licenses,Kassab 40,6,Tex. Disciplinary R. Prof'l Conduct 7.01(a),Rules regarding firm names — cited in connection with unauthorized practice,Kassab 41,6,"Tex. Disciplinary R. Prof'l Conduct 7.03(b), (d)",Prohibition on paying non-lawyers for soliciting/referring clients; prohibition on collecting fees from barratrous employment,Kassab 42,6,"Tex. Disciplinary R. Prof'l Conduct 7.05(a), (c)",Advertising rules — listed in violations section of Exhibit A,Kassab 43,6,"Tex. Disciplinary R. Prof'l Conduct 7.06(a), (b)",Prohibition on accepting or continuing employment procured by prohibited solicitation,Kassab 44,6,Tex. Disciplinary R. Prof'l Conduct 8.03(a),Duty to report known violations of disciplinary rules — cited as Kassab's basis for filing the grievance,Kassab 45,6,"Tex. Disciplinary R. Prof'l Conduct 8.04(a)(1)-(4), (a)(9), (a)(12), (b)","Prohibitions on violating rules, committing serious crimes (including barratry), fraud, barratry, and violating laws relating to practice of law",Kassab 46,6,"S.B. 1716, Acts 2011, 82nd Leg., ch. 94","Senate Bill creating civil liability for prohibited barratry, enacting § 82.0651 with $10,000 penalty provision, effective Sept. 1, 2011",Kassab 47,6,"H.B. 1711, Acts 2013, 83rd Leg., ch. 315","House Bill amending §§ 82.065 and 82.0651 to close loophole allowing attorneys to avoid penalty by releasing clients after signing, aligning with Penal Code § 38.12 and Rule 7.03, effective Sept. 1, 2013",Kassab 48,6,H.B. 1890 (companion bill to S.B. 1716),House companion bill creating civil action for conduct constituting barratry,Kassab 49,7,Tex. Civ. Prac. & Rem. Code § 27.001 et seq.,"Texas Citizens Participation Act (TCPA/Anti-SLAPP) — provides expedited dismissal mechanism for lawsuits based on, relating to, or in response to exercise of free speech, petition, or association rights",Kassab 50,7,Tex. Civ. Prac. & Rem. Code § 27.002,"TCPA purpose — to safeguard constitutional rights of free speech, petition, and association while protecting meritorious lawsuits",Kassab 51,7,Tex. Civ. Prac. & Rem. Code § 27.003,"TCPA motion to dismiss procedure — movant must show claims are based on, relate to, or respond to exercise of enumerated rights",Kassab 52,7,Tex. Civ. Prac. & Rem. Code § 27.005(b)-(d),Two-step TCPA analysis: (b) movant shows applicability by preponderance; (c) nonmovant must establish prima facie case by clear and specific evidence; (d) movant may still prevail by establishing valid defense,Kassab 53,7,Tex. Civ. Prac. & Rem. Code § 27.006,Court must consider pleadings and supporting/opposing affidavits in TCPA analysis,Kassab 54,7,Tex. Civ. Prac. & Rem. Code § 27.009(a),"Mandatory award of court costs, reasonable attorney's fees, and sanctions upon TCPA dismissal",Kassab 55,7,Tex. Civ. Prac. & Rem. Code § 134A.002,TUTSA definitions — defines 'owner' as person in whom rightful title to trade secret is reposed; information is not trade secret if generally known to public,Kassab 56,7,Tex. Civ. Prac. & Rem. Code § 16.003(a),Two-year statute of limitations for conversion,Kassab 57,7,Tex. Civ. Prac. & Rem. Code § 16.010(a),Three-year statute of limitations for trade secret misappropriation from date of discovery,Kassab 58,7,Tex. Penal Code § 38.12(h),Criminal barratry — third-degree felony in Texas,Kassab 59,7,Tex. Disciplinary R. Prof'l Conduct 8.03,Mandatory reporting — lawyer having knowledge of another lawyer's violation that raises substantial question as to honesty or fitness shall inform appropriate disciplinary authority,Kassab 60,8,Tex. Civ. Prac. & Rem. Code § 16.069,"Allows filing of counterclaims arising from the same transaction even if independently barred by limitations, provided filed within 30 days of the answer deadline. Quoted in full.",Kassab 61,8,Texas Penal Code (barratry — third-degree felony),Referenced as the criminal barratry statute; specific section number not cited in text,Kassab 62,8,Tex. Disciplinary R. Prof'l Conduct 8.03,Mandatory reporting of attorney misconduct to the State Bar; cited as basis for Kassab filing grievances,Kassab 74,10,Tex. R. Evid. 602,Requires evidence showing witness has personal knowledge,Kassab 75,10,Tex. R. Evid. 101(h)(4),Definition related to records in the business records context,Kassab 76,10,Tex. R. Evid. 803(6)(A)-(D),Business records exception to hearsay — six elements required for admissibility,Kassab 77,10,Tex. R. Evid. 902(10),Self-authentication of business records — requires proper affidavit establishing custodian qualifications and notice,Kassab 78,10,Tex. Disciplinary R. Prof'l Conduct 1.15(d),"Upon termination of representation, lawyer shall surrender papers and property to which the client is entitled; attorney files belong to client",Kassab 79,10,Tex. Civ. Prac. & Rem. Code § 27.010(b),TCPA commercial speech exception — Kassab argues Pohl failed to prove all four elements,Kassab 80,10,Tex. Civ. Prac. & Rem. Code § 27.006,Court considers pleadings and evidence in TCPA analysis,Kassab 81,11,Tex. Civ. Prac. & Rem. Code § 16.069,"Allows filing of counterclaims arising from same transaction even if barred by limitations, if filed within 30 days of the answer deadline",Kassab 82,11,Tex. Disciplinary R. Prof'l Conduct 8.03,Mandatory reporting of attorney misconduct to the State Bar — cited as basis for Kassab's grievances against Pohl,Kassab 83,12,Tex. Civ. Prac. & Rem. Code § 16.069,"Allows filing of counterclaims arising from same transaction even if barred by limitations, if filed within 30 days of the answer deadline",Kassab 84,12,Tex. Disciplinary R. Prof'l Conduct 8.03,Mandatory reporting of attorney misconduct to the State Bar — cited as basis for Kassab's grievances against Pohl,Kassab 85,13,Tex. Civ. Prac. & Rem. Code § 27.005(d),"Provides that even if plaintiff establishes prima facie case, court must dismiss if movant establishes by preponderance of evidence each essential element of a valid defense",Kassab 86,13,Tex. Civ. Prac. & Rem. Code § 27.009(a),Authorizes sanctions against party who files action subject to dismissal under TCPA in amount sufficient to deter future similar actions,Kassab 109,16,Tex. R. Civ. P. 166a(a),Permits traditional summary judgment motion at any time after adverse party has appeared or answered,Kassab 110,16,Tex. R. Civ. P. 166a(c),Traditional summary judgment standard — no genuine issue of material fact and entitlement to judgment as a matter of law,Kassab 111,16,Tex. Civ. Prac. & Rem. Code § 16.003(a),Two-year statute of limitations for conversion,Kassab 112,16,Tex. Civ. Prac. & Rem. Code § 16.010(a),"Three-year statute of limitations for misappropriation of trade secrets, beginning when misappropriation was or should have been discovered through reasonable diligence",Kassab 113,16,Tex. Civ. Prac. & Rem. Code § 16.010(b),Continuing misappropriation of trade secrets is a single cause of action and limitations begins running without regard to whether misappropriation is single or continuing,Kassab 116,18,Tex. R. Evid. 801(c),Definition of hearsay — out-of-court statement offered for truth of the matter asserted,Kassab 117,18,Tex. R. Evid. 602,Requirement that evidence show how witness has personal knowledge,Kassab 118,18,Tex. R. Civ. P. 166a(c),"Summary judgment standard — affidavits must be clear, positive, and direct",Kassab 119,18,Tex. R. Civ. P. 166a(f),Affidavit must show affirmatively that witness is competent,Kassab 120,20,Tex. Civ. Prac. & Rem. Code § 16.069,"Savings provision allowing counterclaims arising from the same transaction or occurrence to be filed even if independently time-barred, provided filing within 30 days of answer deadline",Kassab 121,20,Tex. Disciplinary R. Prof'l Conduct 8.03,Requires lawyers to report known violations of the disciplinary rules to the State Bar,Kassab 132,23,Tex. Civ. Prac. & Rem. Code § 16.069,"Savings provision allowing counterclaims arising from same transaction or occurrence to be filed even if independently time-barred, within 30 days of answer deadline",Kassab 133,23,Tex. R. Civ. P. 166a(c),Traditional summary judgment standard,Kassab 134,23,Tex. R. Civ. P. 47(a),Requires a short statement of the cause of action sufficient to give fair notice; does not require assignee to identify assignor,Kassab 135,23,Tex. R. Civ. P. 45(b),Requires pleadings to consist of a statement in plain and concise language of the plaintiff's cause of action or defendant's grounds of defense,Kassab 136,23,Tex. Gov't Code § 82.0651,"Civil barratry statute; subsection (a) provides contract-based cause of action for clients; subsections (b) and (d) provide remedies of actual damages, attorney's fees, disgorgement, and civil penalties; subsection (e) mandates liberal construction to protect those in need of legal services",Kassab 137,23,Tex. R. Prof'l Conduct 1.08(h),"Prohibits a lawyer from acquiring a proprietary interest in client's cause of action, but specifically allows a lawyer to acquire a lien granted by law to secure fees or expenses",Kassab 138,23,Tex. Penal Code § 38.12,Criminal barratry statute — felony prohibition on illegal solicitation of clients,Kassab 142,26,Tex. Civ. Prac. & Rem. Code § 33.011(6),"Defines responsible third party as a person who caused or contributed to causing in any way the harm for which recovery of damages is sought, whether by negligent act or omission or by other conduct that violates an applicable legal standard",Kassab 143,26,Tex. Penal Code § 38.12,Defines barratry generally as the improper solicitation of clients,Kassab 144,26,Tex. Disc. R. Prof'l Cond. 8.03(a),"Requires a lawyer having knowledge that another lawyer has committed a violation of applicable rules of professional conduct that raises a substantial question as to that lawyer's honesty, trustworthiness or fitness to inform the appropriate disciplinary authority",Kassab 145,27,Tex. Civ. Prac. & Rem. Code § 16.069,"Allows counterclaims arising from the same transaction to be filed even if independently time-barred, provided filing within 30 days of answer deadline",Kassab 146,27,Tex. Penal Code § 38.12,Referenced as defining barratry as a third-degree felony — improper solicitation of clients,Kassab 147,27,Tex. Disc. R. Prof'l Cond. 8.03,"Requires a lawyer with knowledge of another lawyer's ethical violations that raise substantial question as to honesty, trustworthiness, or fitness to inform the appropriate disciplinary authority",Kassab 156,29,Tex. Civ. Prac. & Rem. Code § 134A.007(a),"TUTSA preemption provision — displaces conflicting tort, restitutionary, and other laws providing civil remedies for misappropriation of a trade secret",Kassab 157,29,Tex. Civ. Prac. & Rem. Code § 134A.005,Authorizes recovery of reasonable attorney's fees when TUTSA claims are made in bad faith,Kassab 158,29,Tex. Civ. Prac. & Rem. Code § 16.069,"Allows counterclaims arising from the same transaction to be filed even if independently time-barred, provided filing within 30 days of answer deadline",Kassab 159,29,Tex. Disc. R. Prof'l Cond. 8.03,Requires a lawyer with knowledge of another lawyer's ethical violations to inform the appropriate disciplinary authority,Kassab 160,30,Tex. R. Disc. P. 17.09,"No lawsuit may be instituted against any complainant or witness predicated upon the filing of a grievance; immunity is absolute and unqualified, extends to all actions at law or in equity",Kassab 161,30,Tex. Civ. Prac. & Rem. Code § 16.010(a),"Three-year statute of limitations for trade secret misappropriation, beginning when misappropriation is discovered or should have been discovered by reasonable diligence",Kassab 162,30,Tex. Civ. Prac. & Rem. Code § 16.010(b),Continuing misappropriation is a single cause of action; limitations begins running without regard to whether misappropriation is single or continuing act,Kassab 163,30,Tex. Civ. Prac. & Rem. Code § 16.003(a),Two-year statute of limitations for conversion of personal property,Kassab 164,30,Tex. Civ. Prac. & Rem. Code § 134A.002(2),'Improper means' includes theft,Kassab 165,30,Tex. Civ. Prac. & Rem. Code § 134A.002(3),'Misappropriation' means acquisition by person who knows trade secret acquired by improper means,Kassab 166,30,Tex. Civ. Prac. & Rem. Code § 134A.002(3-a),"Defines 'owner' of trade secret as person in whom rightful, legal, or equitable title is reposed",Kassab 167,30,Tex. Civ. Prac. & Rem. Code § 134A.005,Court may award reasonable attorney's fees for willful and malicious misappropriation,Kassab 168,30,Tex. R. Civ. P. 58,Statements in a pleading may be adopted by reference in another pleading or motion,Kassab 169,30,Tex. R. Civ. P. 166a(c),Traditional summary judgment standard — no genuine issue of material fact,Kassab 170,30,Tex. Disc. R. Prof'l Cond. 8.03,Duty to report lawyer misconduct to disciplinary authority,Kassab 171,30,Tex. Disc. R. Prof'l Cond. 1.15,Attorney must promptly surrender papers and property to which client is entitled,Kassab 172,30,Tex. Disc. R. Prof'l Cond. 5.05,"Prohibits Texas lawyers from practicing law in jurisdictions where it violates regulation, or assisting unauthorized practice",Kassab 173,30,LA Rev. Stat. 37:213,"Louisiana: felony for unlicensed person to practice law, provide legal advice, or advertise law office",Kassab 174,30,AL Code § 34-3-1 (2021),Alabama: misdemeanor to engage in unauthorized practice of law,Kassab 175,30,Fla. Stat. 454.23,Florida: unauthorized practice of law is a felony,Kassab 176,31,Tex. R. Disc. P. 17.09,No lawsuit may be instituted against any complainant or witness predicated upon the filing of a grievance; immunity is absolute and unqualified,Kassab 177,31,Tex. Civ. Prac. & Rem. Code § 134A.007(a),TUTSA preemption — displaces conflicting tort claims for misappropriation of trade secrets,Kassab 178,31,Tex. Civ. Prac. & Rem. Code § 134A.005,Attorney's fees for bad faith TUTSA claims,Kassab