From: Crimmins, Stephen J. [Crimmins@pepperlaw.com]
Sent: Friday, March 21, 2003 5:12 PM
To: 'rule-comments@sec.gov';
'mailto:rule-comments@sec.gov?subject=S7-04-03:%20'
Subject: Comments on File No. S7-04-03 (Proposed Amendments to Rules of
Pr actice) 

I am a litigation partner with the firm of Pepper Hamilton LLP in
Washington.  I was previously the Deputy Chief Litigation Counsel of the
SEC's Division of Enforcement and a member of the Senior Executive Service.
I have been actively involved in litigating SEC administrative proceedings
for almost 16 years.  

I am writing to adopt the comments filed by the DC Bar Corporation, Finance,
and Securities Law Section on the captioned proposal.  I participated in the
preparation of these comments.  I strongly applaud Commissioner Campos and
other members of the Commission and the Staff for raising these timeliness
issues.  However, I agree with the DC Bar's comments that additional factors
need to be considered to balance the interests of all concerned.  

I would propose that we establish, under Commissioner Campos' leadership, a
task force to promptly evaluate competing suggestions and to make a final
proposal to the Commission.  I would propose that such a task force include
members of the Bar actively involved in defending such proceedings, members
of the SEC Trial Unit actively involved in prosecuting these proceedings,
and if possible, Chief ALJ Murray or her designate.  I would be pleased to
serve under Commissioner Campos on any such effort. 

Stephen J. Crimmins
Pepper Hamilton LLP
------------------Attorneys at Law
600 Fourteenth Street, NW
Washington, DC 20005-2004
Tel: 202.220.1208
Fax: 202.220.1665