fact_id,filing_id,fact
748,60,"Pohl's Motion for Final Judgment filed September 5, 2023; Kassab's Objections filed September 15, 2023; this Reply filed September 18, 2023"
749,60,Jury answered 'Yes' to Q17 after being instructed to only answer 'Yes' if finding was unanimous
750,60,Jury answered Q19 (exemplary damages) which was predicated on unanimous Q17 answer
751,60,Jury did not answer Q18
752,60,Presiding juror appears to have inadvertently failed to sign unanimity certificate for Q17
753,60,Jury assigned 0% fault to Pohl in Q4 (proportionate responsibility tied to trade secrets claim)
754,60,Q3 on Pohl's wrongful conduct was not tied to trade secrets — jury specifically asked if Q3 should be answered even without trade secret finding
755,60,"With agreement of counsel for Kassab, Court instructed jury to answer Q3 even if they answered 'No' to both parts of Q1"
756,60,Kassab requested Q4 be included in jury charge based on proportionate responsibility statute
757,60,Texas trial courts have continued to submit TUTSA and conspiracy claims together to juries
758,60,"Kassab obtained trade secrets from Favre through the November 2016 agreement, not from Precision"
759,60,Jury found Favre bore 10% responsibility for misappropriation
760,60,Kassab designated Precision as a responsible third party; Pohl had no reason to present evidence of Precision's misconduct
761,60,"Kassab previously raised same attorneys' fees arguments in Aug. 29, 2022 Traditional MSJ; Court denied Kassab's request on Oct. 31, 2022"
762,60,"Pohl incorporates prior briefing on Rule 17.09 from Rule 166(g) Motion filed Nov. 30, 2022"
763,60,Kassab's TUTSA expert Joseph Cleveland's article assumes conspiracy can exist alongside TUTSA claims