In Authorlee v. Tuboscope Vetco International, Inc., 274 S.W.3d 111, 119 (Tex. App.--Houston 1st Dist. 2008, pet. denied), the plaintiffs sued the defendant's attorneys for fraud and civil conspiracy, asserting that they had "knowingly agreed to insert false statements" into settlement documents to conceal the existence of an aggregate settlement. The trial court held that "there can be no conspiracy to commit fraud in the litigation setting." Id. at 120. The Court agreed, noting that "it is the type of conduct in which the attorney engages, and not whether it was meritorious in the underlying lawsuit, that governs a party's right to recovery against an adversary's former attorney." Id. And the Court held that all of the complained-of actions by the attorneys "were in connection with the settlement of a lawsuit" and "no private cause of action" exists for litigation conduct. Id.