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Yes, McGrath is off. (MacLeod does not want to formally cancel the
deposition--posturing about the trial date-but he has assured me that he does not really expect McGrath to start on 6/14. I do not intend to prepare McGrath for any examination until July. He may or may not attend Hellmold's deposition to assist me. So for your planning purposes, if not "for the record," McGrath is off.) Are the two of you available for McGrath's deposition in the 7/9-7/12 time frame? I want to get the schedule pinned down right away, because we don't have many dates to work with. Could the three of us talk at 5:00 pm east coast time TODAY? Are you in your respective offices or traveling? Steve Howard phone: 310-407-7613 fax: 310-552-6077 cell: 213-716-0536 e-mail: showard@agsk.com <<< "ClarkB@sullcrom.com" 06/07/01 11:20AM <<< I can talk today or Monday, and I'll be at Malashevich tomorrow. Does this mean that McGrath is definitely off for June 14th? And by the way, everybody fears Frank. -----Original Message----- From: showard@agsk.com [mailto:showard@agsk.com] Sent: Thursday, June 07, 2001 2:07 PM To: razzanof@dsmo.com; clarkb@sullcrom.com Subject: Hellmold Deposition Bruce, is it OK if I notice Hellmold's deposition on 6/13-14 for your offices?? By now you should see that Mr. Hellmold's second report is a 50-page single-spaced document consisting primarily of argument of plaintiff's entire case and written obviously by MacLeod, not Hellmold. MacLeod told me last night that, by virtue of the length and breadth of this second report, MacLeod expects the two of you, in addition to me, to have extensive questions, that he does not intend to argue that you "finished" your questions in the first two-day session of Hellmold's deposition, and that he expects Hellmold's deposition to take up all or substantially all of 6/14 as well as 6/13. We should probably talk live among the three of us about coordinating our approach to this deposition. By the way, I have it on very good authority that Hellmold fears Frank and is not relishing the prospect of further questions from him. (I can fill you in.) Steve Howard phone: 310-407-7613 fax: 310-552-6077 cell: 213-716-0536 e-mail: showard@agsk.com ................................................. ALSCHULER GROSSMAN STEIN & KAHAN LLP ATTORNEYS AT LAW www.agsk.com 2049 Century Park East Thirty-Ninth Floor Los Angeles, CA 90067-3213 Tel 310-277-1226 Fax 310-552-6077 This transmission is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately via e-mail at postmaster@agsk.com or by telephone at 310-277-1226. Thank you. ................................................ ---------------------------------- This e-mail is sent by a law firm and contains information that may be privileged and confidential. If you are not the intended recipient, please delete the e-mail and notify us immediately. ................................................ ALSCHULER GROSSMAN STEIN & KAHAN LLP ATTORNEYS AT LAW www.agsk.com 2049 Century Park East Thirty-Ninth Floor Los Angeles, CA 90067-3213 Tel 310-277-1226 Fax 310-552-6077 This transmission is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately via e-mail at postmaster@agsk.com or by telephone at 310-277-1226. Thank you. ...............................................
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