Message-ID: <26919752.1075860367157.JavaMail.evans@thyme> Date: Mon, 19 Mar 2001 04:00:00 -0800 (PST) From: lysa.akin@enron.com Subject: Ron Carrol call 800-403-2008 Pin #:143570 (Full Details Below) Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Lysa Akin X-To: X-cc: X-bcc: X-Folder: \Mary_Hain_Aug2000_Jul2001\Notes Folders\All documents X-Origin: Hain-M X-FileName: mary-hain.nsf I was asked to set up a conference call for Monday (3/19) at 3:00 Eastern with regulatory and bankruptcy counsel for the nine Complainants to discuss the interrelation between the FERC Chargeback complaint proceeding (and the Amendment 22 matter), the District Court case before Judge Moreno, and the Bankruptcy proceeding, and to discuss strategy. The following issues have been identified as issues for discussion: 1. Likelihood that Bankruptcy Court will grant PX motion to modify stay; including feasibility and effort by parties to file answer in support of motion, including whether it would be realistic to request that the PX's motion be considered on a more expedited basis (PX asked for 3/30 hearing date) in light of the FERC Complaint proceeding; 2. Status and approach for possible settlement with PX for release of collateral assuming Bankruptcy Court modifies stay. 3. Feasibility of asking Bankruptcy Court to immediately release all collateral in excess of amount needed to satisfy (1) vendors, (2) existing and anticipated future defaults of SCE and PG&E, and (3) reasonable costs. In this regard, does anyone have a handle on whether the collateral exceeds the total of the foregoing matters? 4. Any comments on (1) answer to PX answer to Complaint, and (2) answer to PX request for clarification in Amendment No. 22 proceeding; including the timing of such filings with FERC. This email does not address bankruptcy counsel for all parties. If you wish to have your client's bankruptcy counsel on the call, please inform them of the time and relevant information for the call. This call will likely be extremely unwieldy, so I would request the parties to consolidate their participants where possible. Also, please do not forward this information as it addresses confidential litigation matters. Thanks. See you Monday. Ron