Filing Sections
Data license: Public court records
5 rows where filing_id = 54
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| section_id ▼ | filing_id | heading | summary |
|---|---|---|---|
| 409 | 54 54 | Kassab Does Not Agree That His Questions Are Leading, But Pohl's Questions to Favre Were | Kassab disputes Pohl's claim there is 'no dispute' about leading questions — Kassab stated in an email that all objections were meritless. Recites Favre's extensive prior sworn testimony: PMG developed proprietary marketing lists, lists were solely PMG's property, never sold to anyone, freely given to Nicholson. Argues Pohl's DWQ questions suggest Favre perjured himself by suggesting he possessed lists not owned by PMG and needed Pohl's consent to purchase PMG's assets. |
| 410 | 54 54 | Kassab's Questions Are Not Leading | Leading questions are those suggesting a specific desired answer (Implement Dealers, McCormick on Evidence, Wigmore). Lists 16 sample questions Pohl objected to, arguing none suggest which answer is desired. Questions answerable yes/no are not leading unless they suggest which answer is preferred (Wheeler, Newsome). Kassab's questions lack tag phrases like 'isn't it true that' or 'correct' that Pohl's questions contain. Leading questions also permissible to clarify prior testimony or jog exhausted witness's memory (Holbert, McCormick). |
| 411 | 54 54 | Pohl Waived His Objections | Under Tex. R. Civ. P. 193.2(a) and (c), responding party must state specifically the legal or factual basis for each objection at the time it is made. Pohl's boilerplate objections (vague, ambiguous, unduly burdensome, overly broad, etc.) fail this requirement. Failure to comply waives objections under Rule 193.2(e) (In re Soto). |
| 412 | 54 54 | Kassab's Questions Are Not Vague and Ambiguous | Parties have a duty to use common sense interpreting discovery terms (In re Swepi). Typos do not warrant objections. Criticizes Pohl's counsel (a 'Top 100 Super Lawyer') for claiming inability to understand questions with minor typos. Pohl had to reference the attached document to identify the typo, proving they understood the question. |
| 413 | 54 54 | Conclusion & Prayer | Requests the court overrule Pohl's objections to Kassab's DWQ. |
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CREATE TABLE filing_sections (
section_id INTEGER PRIMARY KEY AUTOINCREMENT,
filing_id INTEGER REFERENCES filings(filing_id),
heading TEXT,
summary TEXT
);