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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