Subject: TEAM 4 - HR ENERGY & COMMERCE SUBPOENA (1) (01/14/02) AND (2) (12/10/01)
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked]
Date: Tue, 29 Jan 2002 08:49:50 -0800 (PST)

We remain in the process of gathering information sought by various governmental agencies.

Please search your files and collect all records and documents covered by or relevant to the following requests:

(1)	All records relating to any investigations/review of the allegations raised by Sherron Watkins in her August memo to Ken Lay, including but not limited to:

(A) 		The review conducted by V&E in relation to which you were interviewed.
(B)		Any review conducted by AA.
(C) 	Any relevant internal Enron review.

(2)	All records from investment bankers or other financial advisors,  other than AA,  regarding the structuring, financing or accounting relating to Enron's SPEs, subsidiaries, and/or partnerships including but not limited to LJM1, LJM2, JEDI, CHEWCO, RAPTOR ENTITIES, OSPREY, BLUE DOG, and their subsidiaries.

In the context of the above requests, "records" includes, whether in electronic or hard copy form, all and any emails or regular mail/memoranda you may have sent or received, notes you may have made, documents (including drafts) on shared/hard drives, meeting notes or minutes or actual opinions/advice from any of the above sources.  A full definition provided by the government is attached hereto.

If you discover any records/documents, or if you have any questions, please contact the RAP TEAM at [email-masked] or ext. x5-3723.   

We appreciate that you may have received what appear to be similar requests in relation to other governmental lines of inquiry but it is very important that we respond, and are seen to respond, to each governmental request as specifically, fully and promptly as possible.

Thank you in advance for your continuing assistance in this matter.

Regards,

RAP TEAM

	

ATTACHMENT

1.	The term "records" is to be construed in the broadest sense and shall mean any written or graphic material, however produced or reproduced, of any kind or description, consisting of the original and any non-identical copy (whether different from the origianl because of notes made on or attached to such copy or otherwise); and drafts and both sides thereof, whether printed or recorded electronically or magnetically or stored in any type of data bank, including, but not limited to, the following:  correspondence, memoranda, records, summaries of personal conversations or interviews, minutes or records of meetings or drafts, contracts, agreements, puchase orders, invoices, confirmations, telegraphs, telexes, agendas, books, notes, pamplets, periodicals, reports, studies, evaluations, opinions, logs, diaries, desk calendars, appointment books, tape recordings, video recordings, e-mails, voice mails, computer tapes, or other computer stored matter, magnetic tapes, microfilm, microfiche, punch cards, all other records kept by electronic, photographic, or mechanical means, charts, photographs, notebooks, drawings, plans, inter-office communications, intra-office and intra-departmental communications, transcripts, checks and canceled checks, bank statements, ledgers, books, records or statements of accounts, and papers and things similar to any of the foregoing, however denominated.

2.	The terms "relating," "relate," or "regarding" as to any given subject means anything that consitutes, contains, embodies, identifies, deals with, or is in any manner whatsoever pertinent to that subject, including but not limited to records concerning the preparation of other records.