Subject: Litigation Counsel Approval - Lakeside Packers
From: [email-masked]
To: [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Fri, 11 May 2001 06:35:00 -0700 (PDT)

FYI, following-up on this matter, after discussing the matter with their 
counsel and confronted with a $3.5MM lawsuit, Lakeside acknowledged the deal 
and executed our paper.  Regards, Peter.
---------------------- Forwarded by Peter Keohane/CAL/ECT on 05/11/2001 01:25 
PM ---------------------------
   
	Enron Capital & Trade Resources 
	Canada Corp. 
	
	From:  Peter Keohane                           04/30/2001 10:26 AM

To: James Derrick/Enron@EnronXGate, Mark E Haedicke/HOU/ECT@ECT, Richard B 
Sanders/HOU/ECT@ECT
cc: Mark Taylor/HOU/ECT@ECT, Greg Johnston/CAL/ECT@ECT, Sharon 
Crawford/CAL/ECT@ECT 
Subject: Litigation Counsel Approval - Lakeside Packers

We have a counterparty (Lakeside Packers) who refuses to perform to a 5 year 
fixed for floating power swap which commenced Jan. 01 and is C$2.5MM 
(US$1.7MM) in the money to us and booked (we would take a hit to earnings by 
that amount to unwind the deal).  Unfortunately, without the involvement of 
Legal, the deal was executed without paper, but on the basis that it was 
subject to our standard ISDA documentation.  The Confirm was sent out on that 
basis but not executed by the counterparty.  There was some agreement on 
guarantee support, but as this was less clear to get the underlying deal put 
in place, with the approval of Credit, we gave up the requirement for the 
guarantee in our subsequent discussions and demand letter.

We want to pursue the matter by commencing litigation.

Lakeside is traditionally represented by Blakes.

My suggestion would be to use the Duncan McCachen firm, a litigation boutique 
who we have used in the past (CIBC litigation).  Mike McCachen has a good 
understanding of the trading business for a litigation lawyer.  
Alternatively, I would suggest Clarke Hunter of Macleod Dixon who is 
currently representing us on the NGX litigation and who also has a good 
understanding of out trading business.  Mike is a little more aggressive than 
Clarke, to my preference.

We would like to proceed as soon as possible as our demand letter expired 
last week, and our calls this morning were not dealt with satisfactorily.

Peter.