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  .................................................

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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
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