So it's the word "immediately" that is the problem? Really? I already said in my last post: "Now you say that you never suggested that we file a MSJ. Perhaps that's true (I'll go back and look)....". Any reasonable person would see that as a clear admission that I may be wrong. Apparently that was not good enough for you.

So how about the rest of that paragraph, sans the word "immediately"? Do you intend to simply waddle away from it? This "mismash of partially related concepts"?

"...but you did absolutely say that there is nothing preventing us from filing a MSJ. As suggested in my post, there are multiple issues that IMO prevent a thoughtful party from filing an MSJ before a complete opinion is issued. Further, you did absolutely say that the Judge will not initiate action on preparing his complete opinion until after MSJ is filed. Again, read my post. There are several indicators that we, and the opposition, await issue of the complete opinion before acting."

And no, I haven't bothered to begin reviewing your post history. No rush, things are either there, or they're not. I intend to also capture the other "quotes" in the above paragraph. If they are not there, I will be happy to apologize. And you?

SGE