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To: Bob Kim who wrote (129662)	8/5/2001 12:22:35 AM
From: Glenn D. Rudolph	Respond to of 164684

Glenn, I was referring to traditional "discovery" -- pre-trial info gathering. At least one of the legal experts chiming in on the topic has suggested that the recent settlement may have served to stave off discovery. Another was quick to point out that destroying any potentially discoverable document would be a felony. I agree completely. In fact, that was why I believe Merrill settled. Maybe that was what you said. I just do not believe that Blodget and others (Blodget is the worst in my opinion) have any real basis for many of the calls that were made. There should be some requirement to have projections based on a reasonably person would consider possible revenue and profits. I believe many of the conjectures would fall into the non reasonable area. The discovery though may show in house memos, etc. about investment banking prospects and how Blodget and others should handle it.