assertion_id,filing_id,assertion
896,53,Pohl objected to portions of 100 out of 145 questions in Kassab's DWQ
897,53,Kassab's motion is just over two pages and fails to specify which of Pohl's objections Kassab takes issue with
898,53,Favre has been aligned with Kassab and hostile to Pohl throughout the case history
899,53,"Kassab hired Favre as an expert witness (six-figure up-front payment), Favre was a co-defendant, and Pohl alleges Favre was a co-conspirator with Kassab"
900,53,Kassab initially argued leading questions were proper as 'cross examination' but removed that argument as directly contrary to the Texas Rules of Civil Procedure
901,53,The nonsuit of Favre does not make him hostile to Kassab — Kassab cites no authority for that proposition
902,53,Pohl nonsuited multiple defendants as part of an unsuccessful strategy to prevent trial delay
903,53,"Favre was so ill he could not sit for a full remote Zoom deposition; even when available, his lawyer could not commit he could complete a deposition in a single sitting"
904,53,"Kassab did not secure Favre's consent to a second DWQ, which was necessary since Favre was not subpoenaed"
905,53,"David Wade's actual statement was 'if you ask me that again, i will ask my client to sue' — described as 'facially non-serious'"
906,53,Kassab demanded Wade and Pohl's counsel pay the cancelled deposition invoice the very next day after Favre's hospitalization
907,53,Kassab knew Favre was fighting the flu and had chemotherapy scheduled two days before the December 7 deposition
908,53,Kassab filed his motion complaining about non-response just 30 hours after the first scheduling email
909,53,"The scheduling issue occurred after the leading questions were already served on February 20, 2023, so it cannot retroactively justify them"
910,53,Evidence is not always necessary to support form objections
911,53,"Question #3 contains multiple typos: 'How state how many,' 'compacity,' and 'carrier'"
912,53,Question #15 ('Is PMG a marketing company?') is vague and not limited in time or scope
913,53,Question #18 ('Did PMG compile marketing lists?') calls for speculation since Favre purchased PMG after the alleged activities
914,53,Kassab concedes some questions have 'typos or misspellings' but did not fix them through amended redirect questions