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Privileged and Confidential Joint Defense Communication
To: Grynberg JDT From: Don Schultz Re: Template Answer The Coordinating Counsel Committee has asked me to solicit proposals for a firm to draft and circulate a template answer to the Grynberg complaints. Analysis and drafting of affirmative defenses should be more cost effective for everyone if one firm develops a template. There may also be fact allegations, e.g. those respecting scientific propositions, where efficiency and consistency can be promoted by use of a template. I suggest we aim to have the template available for circulation and comments by June 20th. The separate counsel for individual defendants would retain the responsibility for the sufficiency of the answers filed for their clients. If your law firm is interested in undertaking this scope of work, please send me a very brief proposal to describe how you would staff this and an estimate of the fees involved, for review by the Coordinating Counsel Committee. Dawne M. Davis, CLA Legal Assistant Holland & Hart, LLP P.O. Box 1347 Cheyenne, WY 82003 307-778-4240 307-778-8175 - fax ddavis@hollandhart.com NOTICE: This message is PRIVILEGED AND CONFIDENTIAL. It is sent under the terms and conditions of a Joint Defense Agreement (JDA) and is directed only to recipients who the sender believes have agreed to be bound by the JDA. If you do not agree to be bound by the JDA, or if you believe that this e-mail has been sent to you in error, please reply to notify the sender that you received the message in error, and please delete and disregard this e-mail. Thank you.
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