Pratt V. Westcott (1978)

The memo may ask another justice to write a dissent; a justice may indicate that the dissent will not be assigned right now; memo responding to a dissent assignment (but not accepting assignment, which would be Code 204)

A memo where a justice states that he or she will circulate a dissenting opinion draft, including that a dissenting opinion will be out soon or that a revised draft of the dissenting opinion will be circulated; this also applies to statements responding to dissent assignments like will be glad to write dissent, self-assignment of dissent (e.g., we are in dissent and I will write it), or requesting permission to write dissent (e.g., is it ok if I write a dissent)