United States V. Koecher (1985)

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)

This indicates a memo that informs the Court that an application (e.g., stay, injunction) will be circulated soon; memo about an order

Memo may suggest that the justice talk or discuss an issue at conference; memo may maintain that no further conference discussion is needed; memo may state that a justice will be away