fact_id,filing_id,fact 673,53,Scott Favre is a former co-defendant with ongoing cancer treatment limiting his availability 674,53,"Favre could not sit for a full remote Zoom deposition; even when available, his lawyer could not commit to completing a deposition in a single sitting" 675,53,"Pohl served a DWQ on Favre on February 3, 2023" 676,53,"Kassab served his own DWQ on February 17/20, 2023 with 145 questions" 677,53,"Kassab did not secure Favre's consent to a second DWQ, necessary since Favre was not subpoenaed" 678,53,Pohl objected to 100 of 145 questions 679,53,Kassab made a six-figure up-front payment to Favre 680,53,Kassab claims the payment was to hire Favre as an expert; Pohl alleges it was for misappropriated information 681,53,"Favre's December 7, 2022 deposition cancelled due to hospitalization; Kassab knew Favre was fighting flu and had chemo two days prior" 682,53,Kassab demanded Wade and Pohl's counsel pay the cancelled deposition invoice the next day 683,53,"David Wade's response: 'if you ask me that again, i will ask my client to sue' — characterized as 'facially non-serious'" 684,53,Kassab initially argued leading questions were 'cross examination' then dropped that argument in revised motion 685,53,Pohl's counsel is Jean C. Frizzell of Reynolds Frizzell LLP