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Privileged and Confidential Joint Defense Communication
From:? Don Schultz To:??????Grynberg JDT Re:??????Wright's Motion to Take His Own Deposition ??????????The Wright JDT group authorized me to share the attached draft responsive brief and order prepared by Kirkland & Ellis's Martin Tully.?? Further edits are?underway.???I believe the scheduling discussion and proposal will be cut back to address only the initial?period of?time required to get?documents?and prepare for?the deposition of Wright (rather than looking further down the calendar). ?????????As of last week, the?Grynberg Coordinating Counsel Committee?was inclined to recommend "no action" by Grynberg defendants,?because the deposition issues are?of primary concern to Wright defendants, and because of the probability that the Wright and Grynberg defendants share the same interests as to the deposition schedule and logistics, so that a separate voice for the Grynberg group likely would not?add anything.? The Committe asked me, though, to?monitor what the Wright defendants plan to do and report further. ??????????The Wright Defendants' approach is reflected in their draft motion.??I think it is consistent with what the Grynberg Coordinating Counsel Committee anticipated last week.? ???????? To assure that any proposals for a separate Grynberg filing can be discussed, and that any suggestions this group may want to raise to the Wright drafters, can?be?considered, I asked Dawne Davis to schedule the call?she announced for tomorrow afternoon.? If there is a Wright re-write available?before the call, I will circulate it.? ????????? It may help?the call proceed?more efficiently if you will?email me?any proposals, questions or?concerns you would like to have?raised?for discussion on this topic of Gene Wright's deposition.? Thanks, Don. P.S.? We didn't?try to flood you with emails at the end of today -our outbound internet email was hung up in cyberspace for several hours and then unleashed suddenly.????????? ?????????? - Opposition to Wright Deposition vr10.doc - Opposition to Wright Deposition vr10.wpd - Original Source Scheduling Order v4.doc - Original Source Scheduling Order v4.wpd
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