On Monday Estate has filed a motion objecting every one of Mann's witnesses. Estate still maintains the position that the trial is about determining damages and every other topic & witness is irrelevant.
Today Estate has filed a trial brief. In that trial brief Estate is saying that as they only plan to seek actual damages, Mann/ Vaccaro's state of mind, intent and good faith is irrelevant. Estate says if the court says Mann / Vaccaro's state of mind / intent is irrelevant , Estate will not seek punitive and statuary damages and only will pursue actual damages. However Estate says if the court allows the state of mind be a defense (meaning it was an innocent mistake etc. argument) Estate will counter that and seek punitive and statuary damages.