note your last phrase,

and with all due respect, Handal knows how to preserve error on the collateral estoppel ruling....we don't agree with the judge's "partial" ruling on collateral estoppel....trust me .....plank was not at the sh meeting, but i heard it's not "buried"..

we've got the best of both legal worlds, in plank's opinion, if we get settlements we want fine, if we don't preserve and appeal...

go ahead Handal....respond to that.

sincerely, Plank