Extract to table

This defense is inherently implausible given the forensic evidence (discussed below), but it must be systematically dismantled through discovery

Discovery Objectives The overarching objectives of the discovery plan are fourfold: First, we must establish the complete factual chain of misappropriation

The critical facts that must be proven through discovery include: Harlow's engagement of Archer Material Sciences Inc

Second, we must document the customer solicitation campaign conducted by Amanda Trent and establish the resulting commercial harm to CPS

Third, we must quantify CPS's damages

Discovery must further develop this willfulness evidence, including evidence of Gerald Norris's personal authorization and direction of the scheme