assertion_id,filing_id,assertion 754,45,"Pohl dismissed Favre and Precision as defendants on November 21, 2022, just 14 days before the December 5, 2022 trial" 755,45,Favre and Precision are central to the litigation as they purchased all documents from Walker/Ladner/Seymour and gave some to Kassab 756,45,Favre and Precision are outside the subpoena power of the court 757,45,Kassab has attempted to depose Favre and Precision for more than a year without success 758,45,Good cause exists for late designation due to Pohl's timing of dismissal creating prejudice to Kassab 759,45,Favre and Precision certified and represented to Kassab that all materials were owned by them after purchase 760,45,"Walker, Ladner, and Seymour certified they owned all assets when selling to Favre" 761,45,Kassab relied on these representations when receiving the subject documents 762,45,Kassab could not have misappropriated any alleged trade secret by improper means given these representations 763,45,All 10 designated parties should be subject to fault apportionment by the jury