assertion_id,filing_id,assertion
915,54,Kassab's questions are not leading because they do not suggest a specific desired answer
916,54,Questions answerable with 'yes' or 'no' are not leading unless they suggest which answer is desired
917,54,"Kassab's questions lack tag phrases like 'didn't he,' 'isn't it true that,' 'would you agree,' or 'correct' — unlike Pohl's questions"
918,54,"Pohl's DWQ questions to Favre are themselves leading, designed to suggest Favre perjured himself in prior sworn testimony"
919,54,"Favre previously testified under oath in affidavit and in federal court: PMG developed proprietary marketing lists solely PMG's property, lists never sold, Favre freely gave them to Tina Nicholson"
920,54,Favre testified 'PMG's marketing lists constitute one of PMG's most valuable assets'
921,54,Favre testified PMG's marketing lists contain names of thousands of persons who became Pohl's former clients
922,54,Favre testified Pohl and Billy Shepherd 'could care less if that list gets out there or not'
923,54,"After Pohl nonsuited Favre without any settlement terms, Pohl 'in cahoots with Favre's counsel, David Wade, sent DWQs designed to contradict Favre's prior testimony'"
924,54,Pohl's boilerplate objections fail to state specifically the legal or factual basis as required and are therefore waived
925,54,Kassab attempted to take Favre's deposition for more than two years but Favre resisted
926,54,Favre admits he is exhausted and cannot sit for a normal deposition
927,54,DWQ is the only available mechanism to get usable testimony from Favre given his health limitations
928,54,"Kassab provided documents to refresh Favre's memory, which is permissible"
929,54,"Pohl's leading objections were directed at DWQ questions 15-19, 24-26, 29, 31-39, 45-47, 53, 56-70, 73-79, 91-96, 109-112, 114-118, 120-122 and 129-145"
930,54,"Pohl had to reference the attached document to identify typos, proving they understood the question despite objecting to vagueness"