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Key Assertions

1,237 material factual assertions from filings

Data license: Public court records

19 rows where filing_id = 53

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assertion_id ▼ filing_id assertion
896 53 53 Pohl objected to portions of 100 out of 145 questions in Kassab's DWQ
897 53 53 Kassab's motion is just over two pages and fails to specify which of Pohl's objections Kassab takes issue with
898 53 53 Favre has been aligned with Kassab and hostile to Pohl throughout the case history
899 53 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 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 53 The nonsuit of Favre does not make him hostile to Kassab — Kassab cites no authority for that proposition
902 53 53 Pohl nonsuited multiple defendants as part of an unsuccessful strategy to prevent trial delay
903 53 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 53 Kassab did not secure Favre's consent to a second DWQ, which was necessary since Favre was not subpoenaed
905 53 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 53 Kassab demanded Wade and Pohl's counsel pay the cancelled deposition invoice the very next day after Favre's hospitalization
907 53 53 Kassab knew Favre was fighting the flu and had chemotherapy scheduled two days before the December 7 deposition
908 53 53 Kassab filed his motion complaining about non-response just 30 hours after the first scheduling email
909 53 53 The scheduling issue occurred after the leading questions were already served on February 20, 2023, so it cannot retroactively justify them
910 53 53 Evidence is not always necessary to support form objections
911 53 53 Question #3 contains multiple typos: 'How state how many,' 'compacity,' and 'carrier'
912 53 53 Question #15 ('Is PMG a marketing company?') is vague and not limited in time or scope
913 53 53 Question #18 ('Did PMG compile marketing lists?') calls for speculation since Favre purchased PMG after the alleged activities
914 53 53 Kassab concedes some questions have 'typos or misspellings' but did not fix them through amended redirect questions

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CREATE TABLE key_assertions (
    assertion_id INTEGER PRIMARY KEY AUTOINCREMENT,
    filing_id INTEGER REFERENCES filings(filing_id),
    assertion TEXT
);
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