fact_id,filing_id,fact 686,54,Kassab attempted to depose Favre for more than two years 687,54,Favre has resisted being deposed; admits he is exhausted and cannot sit for a normal deposition 688,54,DWQ is the only available mechanism to get usable testimony from Favre 689,54,Favre purchased PMG from Scott Walker and Kirk Ladner in May 2016 690,54,Favre testified PMG developed proprietary marketing lists that were solely PMG's work product and property 691,54,Favre testified PMG's marketing lists were never sold to anyone 692,54,Favre testified he freely gave PMG's marketing lists to Tina Nicholson 693,54,Favre testified Pohl and Billy Shepherd 'could care less if that list gets out there or not' 694,54,Pohl nonsuited Favre without any settlement terms 695,54,Pohl objected to 100 of 145 DWQ questions 696,54,Pohl's DWQ questions suggest Favre should contradict his prior sworn testimony