Subject: Teresa Lorraine Simmons v. Enron Corp.
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked]
Date: Wed, 30 May 2001 11:30:33 -0700 (PDT)

Mr. Derrick, I am directing this email to your attention at the request of Mr. Jim Bouillion for consideration of extending coverage to Enron Corp., pursuant to the EMPLOYMENT PRACTICES LIABILITY ENDORSEMENT on our Directors & Officers policy.

We have received a new Petition wherein a former employee of Enron Corp. (former Vice President of Operations for Enron Communications in Portland, Oregon) alleges damages as a result of sexual discrimination and retaliation along with wrongful termination.  Suit is filed in Harris County, Texas, with an Answer date of June 18, 2001.  Essentially, the Plaintiff claims to have been harassed by Ken Griebling in such a way that he created a "hostile work environment".  She filed a complaint with HR and Ken Rice, to no avail.  She was later advised her position was being eliminated and that her responsibilities were being assigned to Ken Burroughs, who she had hired and trained.  She was in turn assigned to a bandwidth trading floor position with no defined responsibilities wherein she was terminated shortly thereafter under the alleged pretext that her position had been eliminated.

Our preliminary review of the Plaintiff's Original Petition (absent any independent investigation or knowledge with respect to her allegations and the valued placed on same-pleadings allege an unspecified amount of damages) suggests there might be coverage for this loss under the Directors & Officers policy.  The definition of "WRONGFUL EMPLOYMENT PRACTICE" includes "discrimination" which is defined as both the termination of an employee and the treatment of an employee in disparate manner from other similarly-situated employees in respect to a employee's sex, or in violation of any equivalent protection or rights which may have been conferred on any group or individual protecting them against employment discrimination under federal, state, or local law.

Please advise if you would like for us to extent coverage to the named defendant, Enron Corp.  According to the information provided, the matter has been assigned to C. Robert Vote of the Litigation Unit.

Thanks,

Rob Cole, Manager-Claims
ENA - Global Risk Markets
P.O. Box 1188 (77251-1188)
1400 Smith Street, EB2136F
Houston, Texas  77002
713-853-7739 (telephone)
713-646-2341 (facsimile)
[email-masked] (email)