Message-ID: <31213364.1075859799296.JavaMail.evans@thyme> Date: Wed, 18 Apr 2001 03:34:00 -0700 (PDT) From: bogden@ogwb.com To: richard.b.sanders@enron.com, lgibson@ogwb.com, elizabeth.sager@enron.com, ebaughm@enron.com, bonnie.white@enron.com, andrew.edison@enron.com, mark.e.haedicke@enron.com Subject: Calpine Depositions Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: "Bill W. Ogden" X-To: "Richard Sanders" , "Laura Gibson" , "Elizabeth Sager" , "Ed Baughman" , "Bonnie White" , "Andy Edison" , "Mark Haedicke" X-cc: X-bcc: X-Folder: \Mark_Haedicke_Jun2001\Notes Folders\All documents X-Origin: Haedicke-M X-FileName: mhaedic.nsf I have spoken this morning with Tom Ganucheau, Calpine's lawyer, and confirmed that the depositions of Calpine witnesses are on for next week. Tom is juggling schedules with the witnesses, and I told him we'd accomodate their schedules, but I wanted him to give me a batting order by this Friday, April 20, which he said he could do. The following people are scheduled to be deposed: Carey Jordan, Steve Snow, Paul Posoli, and Darryl Hayslip. Mr. Jordan will double as the CPSC corporate rep, and I told Tom I had no problem taking his deposition once and agreeing that it covered both his individual notice and the corporate rep notice. Tom is still working on who will be named as the Calpine Corp. corporate rep, and will advise us. It will be very helpful if either Elizabeth or Ed can be present for at least part of these depositions, especially Snow and Jordan. At a minimum, please jot down (or reply email) your thoughts as to any points you want to be sure we cover with these witnesses. Cross examination of an adverse witness in circumstances like this is much more effective when the Enron rep knowledgable about the transaction is in the room, both to deter exaggeration from the witness, and to serve as a resource for following up on incorrect or evasive answers. The summary judgment reply is due this Friday and will be filed on time. A current draft was circulated yesterday evening to Bonnie and to Andy, along with the current draft affidavits for Sager, Baughman, Bradford and Vollmar. Sager's affidavit is signed and has been returned to me. Baughman called yesterday with revisions and Bradford called this morning; we are still waiting on the damage information to fill in the last paragraph of Baughman's affidavit. Please let me know if any of you need current copies of the brief or any affidavits, and please do not hesitate to call if you have any questions or comments. Best regards, Bill Ogden Tel: 713-844-3001 Fax: 713-844-3030 email: bogden@ogwb.com