Letter from Wright defendants.  Conference call went fine.

>  -----Original Message-----
> From:  Tetrault, Charles D.
> Sent: Tuesday, December 12, 2000 12:52 PM
> To: Thomas A. Nicholas (E-mail); David Zott (E-mail)
> Subject: Letter to Judge Downes
>
> Minor drafting suggestion.  Beginning of the third paragraph.
>
> Delete "In connection with the first scheduling conference," and
> substitute "At the appropriate time,".
>
> Reason: Judge Downes already in some respects has a de facto scheduling
> order based on what he has said at various hearings.  It seems likely that
> he will get to public disclosure / original source after the pending
> motions are resolved.  This is consistent with the goals of the Wright
> defendants' letter.
>
> If there is a scheduling conference in the near future (and the letter
> does not suggest that there should be), we will face the demand from the
> relators that "core" discovery (read "merits" discovery) should proceed
> during the pendency of the motions practice.  So, I simply would prefer
> not to use the phrase "first scheduling conference."
>
>
> Charles D. Tetrault
> Vinson & Elkins L.L.P.
> 1455 Pennsylvania Ave., N.W.
> Washington, D.C. 20004-1008
> ctetrault@velaw.com
> 202.639.6551 [voice]
> 202.639.6604 [fax]
>
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