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