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The “maximum of two drafts” rule for memos at Schering-Plough

PD Villareal, Schering-Plough’s lead litigation counsel, contributed a piece on ten ways to survive litigation stress (Inside Litigation, Winter 2006 at 13). In the middle, under the heading “Edit the Editing,” he notes, quite correctly, that “none of us writes like Proust or Flaubert.” Less correctly he imposes the rule that therefore “you’re allowed a maximum of two drafts” because “real men (and women) only need one draft.”

He’s right to root out the over-working of memos, but it’s the rare lawyer who can turn out quality (or even workmanlike) prose on just the second time through.

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