defense_id,filing_id,defense 250,40,Pohl's declaration testimony is conclusory and inadmissible throughout 251,40,Pohl's ownership and trade secret claims are improper legal conclusions from a lay witness 252,40,Pohl's references to 'Precision' are too vague for interested-witness standard 253,40,Grievance dismissals are irrelevant to civil liability and inadmissible hearsay 254,40,Santana letter and audio transcription are inadmissible hearsay 255,40,Zavitsanos fee report is unsworn hearsay 256,40,Pohl Deposition excerpt contains hearsay about what third parties told Nicholson