Subject: Affidavit in support of motion to compel
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Fri, 13 Apr 2001 08:14:00 -0700 (PDT)

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