CONTACTS 
0201 - Thelen, Marrin, Johnson & Bridges  415 392 6320
020101 - Mr. David Buoncristiani, Esq.

SUBJECTS
SDS Marketing, Perceived Value
Discovery, Strategic Resource
Sales Resistance
Admissibility, 930830
Discovery, Strategic Resource
Demonstrations

0708 -    ..
0709 - Summary/Objective
0710 -
071001 - Showed SDS to get David's reaction to admissibility question raised by
071002 - Bob Denmark of PMI at demo last week, ref SDS 3 line 061357.
071003 -
071004 -
0711 -
0712 -
0713 - Discussion
0714 -
071401 - Welch v. State
071402 -
071403 - David mentioned he is involved with Hi Dillon and Irving Perluss on a
071404 - State arbitration matter Dave is handling.  He was unaware of Hi's
071405 - involvement in Welch, so I recounted that early history.
071406 -
071407 -
071408 - Automated Citations
071409 -
071410 - Did not have time to use Wilson Miller v. Llama at ref SDS 2 line
071411 - 040601, to show how a case analysis, or brief, can be written using
071412 - SDS records of hearing as citations.  He did explore the citation
071413 - feature though on the "discovery" issue, so I think he has the general
071414 - idea.
071415 -
071416 - I noticed David had a monitor, keyboard and mouse on his desk, so
071417 - invited him to be the "pilot" taking us through various SDS features.
071418 - Once he caught on that the right button only opens menus and the left
071419 - button does everything else, he was flying.
071420 -
071421 -
071422 -      Schedule
071423 -
071424 -      Briefly explained distinction between performed tasks and
071425 -      pending.  Color codes show priority.
071426 -
071427 -            Detail on any task can be obtained by double clicking or
071428 -            pressing enter ("controlled visibility" design).
071429 -
071430 -            This shows contacts involved, prior related events,
071431 -            documents and files, plus notes to guide performance.
071432 -
071433 -            Pressing F8 converts a "scheduled" task into a "Diary"
071434 -            record, where user can enter what actually occurred, if
071435 -            necessary, plus connect it with prior understandings.
071436 -
071437 -
071438 -      Diary
071439 -
071440 -      David used F3 and the menu interchangeably to obtain chronologies
071441 -      of past work, showing information can be obtained instantly for
071442 -      yesterday, or 2 years ago, and can apply "keywords."
071443 -
071444 -
071445 -      Electronic Notebook
071446 -
071447 -      Dave recognized quickly how SDS is an electronic notebook, that
071448 -      ties together what we do and think with related information, such
071449 -      as briefs, memos, correspondence, so everything needed to accomp-
071450 -      lish a task is immediately at hand, if needed, but otherwise does
071451 -      not clutter up the desk.
071452 -
071453 -
071454 -      Linked Records for Follow Up
071455 -
071456 -      As an experiment, Dave scheduled a test "follow up" task using
071457 -      this record with the menu tools, to see how current activity is
071458 -      automatically linked to its history for instant access.
071459 -
071460 -
071461 -      Subjects
071462 -
071463 -      Showed how records can be tagged with subjects related to
071464 -      projects, cases, or any organizing criteria.  David was able to
071465 -      step through succeeding levels of detail going forward, and
071466 -      backward, just by clicking in back of or in front of a subject
071467 -      description.
071468 -
071469 -      Did a report on the "Discovery" subject.
071470 -
071471 -      David asked about how easy it is to assign multiple subjects to a
071472 -      body of text, so we did a few of these to show it only takes a
071473 -      second.  This makes traditional "filing" a matter of mere intel-
071474 -      lectual volition.
071475 -
071476 -
071477 - Project Management Support
071478 -
071479 - Submitted the SDS & POIMS scope statement, ref OF 3, and product
071480 - brochure.  He feels SDS could be helpful to project managers.  I need
071481 - to get his opinion about how well SDS accomplishes the explanation in
071482 - the scope statement, particularly "command and control" of the record
071483 - as set out at ref OF 3 line 351.
071484 -
071485 -
071486 - SDS Records Admissible Evidence
071487 -
071488 - On the central point of admissibility raised at ref SDS 3 line 061357,
071489 - Dave feels SDS records meet all of the standard tests.
071490 -
071491 -
071492 - Discovery May be Limited
071493 -
071494 - We considered the discoverability issue framed in part by the dialog
071495 - at ref OF 2 line 15.  Initially considered our previous discussions in
071496 - 1991, per ref SDS 1 line 071305, arising from concerns expressed by
071497 - Sarah Bond at DNRC, and others.
071498 -
071499 - I explained my own experience of responding to subpeonas and interoga-
071500 - tories by submitting printed material extracted from the data base
071501 - and/or computer files on a disk containing only those parts of record
071502 - with relevant information, in the same way one would answer a deposi-
071503 - tion question.  David feels current practice might permit wider
071504 - access, depending upon the specifics of a particular case, and noted
071505 - discovery has been permitted to E-Mail in some cases which often is
071506 - viewed by Users as "private" discussion.  He agreed that in general
071507 - communications between a consultant and a party's counsel, and/or
071508 - between a party and its counsel, would be afforded some priviledge.
071509 - Since the SDS data base is a chronology of related, unrelated, as well
071510 - as privileged communications, the originator should be entitled to
071511 - extract such protected information.
071512 -
071513 -
071514 -
071515 -
0716 -