Message-ID: <27826558.1075859585152.JavaMail.evans@thyme>
Date: Fri, 13 Apr 2001 08:14:00 -0700 (PDT)
From: lgibson@ogwb.com
To: bonnie.white@enron.com, elizabeth.sager@enron.com
Subject: Affidavit in support of motion to compel
Cc: andrew.edison@enron.com, bogden@ogwb.com
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X-From: "Laura Gibson" <lgibson@ogwb.com>
X-To: "Bonnie White" <bonnie.white@enron.com>, "Elizabeth Sager" <Elizabeth.Sager@enron.com>
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As I believe I have discussed with each of you, Calpine has refused to
produce contract summaries for contracts outside of ERCOT. Its stated bases
are: 1. Enron limited its requests to ERCOT (not true); and 2. customs vary
depending upon the NERC region.

Elizabeth, I would like to prepare an affidavit for you which tracks
paragraph 12 of draft 4 of your affidavit which was faxed to you yesterday
and which adds a sentence which says something to the effect of: "This
custom and practice of providing a parent guarantee as described above did
not vary depending upon the particular National Electric Reliability Council
("NERC") region involved in the contract."

Please let me know whether this addition presents a problem. I will need to
file our motion to compel on Monday. Bill Ogden and I will be meeting with
Bonnie and Bill Bradford at 1:30 and can coordinate the execution of
Elizabeth's affidavit while we are in the building. I look forward to
hearing from you. Laura Gibson