Message-ID: <15214591.1075859593569.JavaMail.evans@thyme>
Date: Wed, 23 May 2001 07:47:00 -0700 (PDT)
From: bonnie.white@enron.com
To: elizabeth.sager@enron.com
Subject: Calpine:  ATTORNEY CLIENT PRIVILEGED COMMUNICATION
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Elizabeth,
Your deposition has been rescheduled for Wednesday, June 13, 2001, at 10:00 
am.  I understand from your assistant that you are available on that date.  
(I remain hopeful that we will have the matter resolved by then, but we were 
not in a position to indefinitely postpone rescheduling the depo, and we 
pushed it out about as far as we reasonably could).  Please review the 
subpoena duces tecum that was attached to your original deposition notice to 
determine whether you have any responsive documents that have not been 
previously produced.  In particular, please determine whether you have any 
notes, calendar entries, or contract negotiation files that have not been 
previously produced.  If you have any responsive documents that you believe a 
covered by the attorney-client privilege or attorney work product privilege, 
please let  me know about them anyway, so that we can make sure to disclose 
them properly to preserve the privilege.  Also, we will need to schedule a 
deposition prep meeting, assuming the deposition goes forward.  Please let me 
know when you have a couple of hours to meet with me and outside counsel to 
prepare.  If you have time available on Thursday, June 7, that would be a 
good time to try to schedule it.  Otherwise, let me know your availability.  
We will do what we can to make this as painless as possible.  Thanks.

Bonnie J. White
Enron Litigation Unit
1400 Smith Street, Suite 4824
Houston, TX  77002
Ph:  713-853-7244
Fax: 713-853-6576
bonnie.white@enron.com