Message-ID: <24734398.1075840500549.JavaMail.evans@thyme> Date: Mon, 18 Mar 2002 15:41:18 -0800 (PST) From: sproctor@akllp.com To: chris.germany@enron.com Subject: FW: Motion filed 3/12 Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: "Proctor, Shemin V." @ENRON X-To: Germany, Chris X-cc: X-bcc: X-Folder: \ExMerge - Germany, Chris\Bankrupt\Transport\Dominion X-Origin: GERMANY-C X-FileName: chris germany 6-25-02.pst Here are the exhibits. -----Original Message----- From: Kelly, Neil [mailto:Neil.Kelly@ENRON.com] Sent: Monday, March 18, 2002 4:24 PM To: Proctor, Shemin V. Subject: RE: Motion filed 3/12 attached are the copies of the exhibits -----Original Message----- From: Proctor, Shemin V. [mailto:sproctor@akllp.com] Sent: Monday, March 18, 2002 3:46 PM To: Kelly, Neil Subject: RE: Motion filed 3/12 Neil, Do you have a copy of the exhibits which were attached to the motion? The pdf file appears to contain only the body of the motion. Also, I keep stopping by, but I haven't seen you. Are you here at Enron? Shemin -----Original Message----- From: Kelly, Neil [mailto:Neil.Kelly@ENRON.com] Sent: Tuesday, March 12, 2002 7:06 PM To: Sharp, Vicki; Mann, Kay; Gray, Barbara N.; Aronowitz, Alan Cc: Proctor, Shemin V.; Ellenberg, Mark Subject: Motion filed 3/12 The following motion was filed today, March 12: Motion of Dominion Transmission, Inc. for Entry of an Order (a) Granting relief from the stay so as to enable transfer of gas stranded in pipeline to alternate pool operator; and (b) compelling the debtors to pay Administrative Post-Petition Parking Charges Enron entities involved: EES and ENA Hearing: April 4, 2002 Objection deadline: April 1, 2002 <> Summary of relief sought: EES is a party to approximately 35 contracts with different natural gas producers that utilize Dominion's pipeline to transport and store gas as requested by EES. ENA is a party to approximately 236 contracts with natural gas producers that also use Dominion's pipeline. EES and ENA are parties to transportation and pooling agreements with Dominion that expressly provide for use of Dominion's pipepline for gas purchased by from the producers. Dominion alleges that EES and ENA continue to use Dominion's pipeline because their gas purchase agreement with the producers have not been terminated. Dominions contends that the gas has been stranded on its pipeline and continues to accumulate, but EES and ENA have not paid Dominion for "parking" or storage charges or paid the producers for the value of the gas placed into Dominion's pipeline. Further, ENA and EES allegedly have failed to move the gas out of their pool by transfer or release the gas from the pool for sale to another pool operator. Dominion requests relief from the stay to transfer gas stranded on its pipeline to alternate pool operators and to obtain payment as administrative expenses the parking charges for gas stranded on the pipeline. Domion's only argument that the alleged parking services somehow benefitted the estate is that ENA and EES have been able to hold natural gas ready to deliver on short notice to various end users. ********************************************************************** This e-mail is the property of Enron Corp. and/or its relevant affiliate and may contain confidential and privileged material for the sole use of the intended recipient (s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender or reply to Enron Corp. at enron.messaging.administration@enron.com and delete all copies of the message. This e-mail (and any attachments hereto) are not intended to be an offer (or an acceptance) and do not create or evidence a binding and enforceable contract between Enron Corp. (or any of its affiliates) and the intended recipient or any other party, and may not be relied on by anyone as the basis of a contract by estoppel or otherwise. Thank you. ********************************************************************** - Ex A.pdf - Ex B.pdf - Ex C.pdf - Ex D.pdf - Ex E.pdf