filing_sections: 76
Data license: Public court records
This data as json
| section_id | filing_id | heading | summary |
|---|---|---|---|
| 76 | 10 | Objections — Plaintiffs' Exhibit B (Declaration of Michael A. Pohl) | Objects to Paragraphs 3 through 9 of Pohl's declaration as conclusory and constituting no evidence as a matter of law. Challenges each paragraph individually: Para 3 (ownership of trade secrets — fails to describe what information is or explain ownership vs. Favre's claim); Para 4 (wrongful dominion — no factual support for why Kassab's control over lists obtained from Favre is wrongful); Para 5 (damages — doesn't identify trade secrets or explain how damaged); Para 6 (substantial measures to maintain confidentiality — conclusory, information ended up in Favre's hands); Para 7 (independent economic value — no underlying facts, doesn't describe materials or how they provide economic value); Para 8 (misappropriation and unjust enrichment — no facts explaining how, purported loss is speculative); Para 9 (conspiracy — conclusory statement within a conclusory statement, no facts supporting alleged conspiracy claims). |