Privileged and Confidential Joint Defense Communication

To:      Grynberg JDT
From:  Don Schultz
Re:      Template Answer

           The Coordinating Counsel Committee has asked me to solicit 
proposals for a firm to draft and circulate a template answer to the Grynberg 
complaints.   Analysis and drafting of affirmative defenses should be more 
cost effective for everyone if one firm develops a template.  There may also 
be fact allegations, e.g. those respecting scientific propositions, where 
efficiency and consistency can be promoted by use of a template.   I suggest 
we aim to have the template available for circulation and comments by June 
20th.  The separate counsel for individual defendants would retain the 
responsibility for the sufficiency of the answers filed for their clients.   
If your law firm is interested in undertaking this scope of work, please send 
me a very brief proposal to describe how you would staff this and an estimate 
of the fees involved, for review by the Coordinating Counsel Committee.

Dawne M. Davis, CLA
Legal Assistant
Holland & Hart, LLP
P.O. Box 1347
Cheyenne, WY  82003
307-778-4240
307-778-8175 - fax
ddavis@hollandhart.com

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