Privileged and Confidential Joint Defense Communication

To:     Grynberg JDT Participants
From:  Don Schultz
Re:     Deadline Tomorrow - 3 points.
          1.  Attached is a draft letter to Judge Downes as discussed in this 
afternoon's telephone conference.  Please share any feedback or edits as soon 
as you can, as this needs to be filed tomorrow.
          2.  I asked Dana Eismeier if Grynberg plans to file anything on 
this Wright motion.  He said Hosie has a footnote in his motion to assert no 
other relators should be permitted to participate in the deposition.  This 
was a hostile reaction to the letter Grynberg counsel had sent to Hosie on 
the subject.  For tomorrow, Eismeier wants to refrain from the high state of 
animosity that has marked prior exchanges with Hosie and so plans to file a 
motion to extend the deadline for a week to promote discussions to work 
something out.  If they don't work something out Grynberg will file something 
to demand participation.   I don't think this changes what we discussed today 
and think we should go ahead to finalize our letter.
         3.  Attached is a revision of the Wright group brief.  This version 
goes further in proposing schedule steps for original source issues than I 
expected the rewrite would go (and predicted in this afternoon's call).  
Please take a look at this version.   Let me know if you feel we should 
arrange a call fairly early tomorrow to try to provide feedback to the Wright 
drafters, or, send me your comments to be collected and forwarded to those 
folks.  Thanks.


 - 2811848_1.DOC
 - Opposition to Wright Deposition vr11.doc
 - Opposition to Wright Deposition vr11.wpd