Subject: RE: Enron DOAH Pompano Orders of 8/23/01
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked]
Date: Wed, 29 Aug 2001 09:12:01 -0700 (PDT)

Steve, 
         I sent to you and Kay by email yesterday morning, the initial plan
for the first phase of the discovery process along with time frames for
preparation and a request for authorization to proceed.   We would like to
issue the discovery as soon as reasonably possible after authorization,
given the relatively short time frame until the Pompano Beach hearing.   Kay
wants to discuss the discovery proposal and I expect that we will be doing
so sometime very soon.  (Kay, I am available all afternoon and also
available for most of the day tomorrow).   
        The discovery efforts proposed are independent of DEP.  Thus, we
will not be tied to or delayed by DEP, should the agency fail to undertake
the discovery that is needed.   Ryan Reetz of my office will be the lead
attorney responsible for that effort.   The petitioning municipalities and
Broward County agencies will likely conduct their own discovery, which may
include seeking to depose  Enron's experts and/or an Enron corporate
representative.   
        With respect to our experts, I had previously asked that Dave
Kellermeyer identify certain expert witnesses that we may need to sustain
the issuance of the permit.   By copy of this email, I am asking that Dave
contact me to advise me of the status of his efforts to date.         
          I hope that the foregoing answered all of your questions but
please advise me if I can be of further assistance. 
         --Kerri 
 
-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Saturday, August 25, 2001 9:44 PM
To: [email-masked];
[email-masked]; [email-masked]; [email-masked]
Cc: [email-masked]; [email-masked]; [email-masked];
[email-masked]
Subject: RE: Enron DOAH Pompano Orders of 8/23/01

With an Oct 29 hearing date and the fact that Coral Spring's key expert is
out on vacation the entire month of September and our DEP friends are
frequently out of the office, we need to come up with an action plan &
schedule.

Kerri- please determine DEP's involvement & availability and fold into a
draft schedule.  Do we have an expert witness?  Who will be involved in the
discovery process?

Steve

 -----Original Message-----
From:     [email-masked]@ENRON
          [mailto:[email-masked]]
Sent:     Friday, August 24, 2001 6:50 PM
To:       Krimsky, Steven; Kellermeyer, Dave; Grube, Raimund;
          [email-masked]
Cc:       Mann, Kay; Thode, Eric; Sooter, Lea; [email-masked]
Subject:  FW: Enron DOAH Pompano Orders of 8/23/01

            I am attaching for your review two orders issued by Judge
Stampelos yesterday, which we have not officially received but obtained
from
the DOAH website.   The first is a Notice of Hearing, including all of the
logistical information on the four-day hearing commencing on October 29th
and concluding on November 1st.   The second is the order of Pre-hearing
Instructions, which is typically issued along with the Notice of Hearing.
The Pre-hearing Notice is primarily directed to legal counsel for the
parties, requiring that such counsel confer fifteen days prior to the date
of the final hearing to prepare a pre-hearing stipulation, discuss the
possibility of settlement, examine exhibits and otherwise prepare for the
hearing.
             Please call me if you have any questions on the attachments.
                --Kerri

>  -----Original Message-----
> From:   Savage, Paul (Assoc-Mia-App)
> Sent:   Friday, August 24, 2001 4:18 PM
> To:     Barsh, Kerri (Shld-Mia-Env)
> Subject:     Enron DOAH Pompano Orders of 8/23/01
>
> Kerri:
>
> A notice of hearing and an order of prehearing instructions issued
> yesterday in the Pompano proceeding.  They are attached.  The Broward
> intervention motion remains outstanding.  No activity is reflected in
> Deerfield.
>
>  <<DOAHPompanoprehearinginstruct.pdf>>
<<DOAHPompanoprehearingorder.pdf>>
>
>
> Thanks,
>
> Paul C. Savage
> Greenberg Traurig, P.A.
> ph. (305) 579-0720
> fax (305) 961-5720
> [email-masked]
>
>
>
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 - DOAHPompanoprehearinginstruct.pdf << File:
DOAHPompanoprehearinginstruct.pdf >>
 - DOAHPompanoprehearingorder.pdf << File: DOAHPompanoprehearingorder.pdf
>>

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