Subject: PCA Demand Letter
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked]
Date: Mon, 14 Aug 2000 05:26:00 -0700 (PDT)

CONFIDENTIAL
ATTORNEY/CLIENT INFORMATION
NOT DISCOVERABLE

Two years after PCA's bankruptcy, we received a demand letter from PCA.  PCA 
claims that EPMI owes PCA $15,126,445.16 for damages resulting from EPMI's 
wrongful termination of transactions in June 1998.  This amount appears to be 
based on PCA's calculation of the forward values of the terminated trades, 
and certain "preference payments" that PCA claims were made to EPMI.  This 
claim is in its preliminary stages.  I will update you with further 
information as soon as we get a handle on what the Trustee is really 
seeking.  As you will remember, we currently have a proof of claim pending 
against PCA for over $5 million dollars representing our unpaid receivable 
amount.

Bill

In connection with this matter, it would be very helpful if you could have 
someone gather the following information:

1.  Date and amount of last payment made by PCA, splitting the relative net 
amounts owed to and from EPMI (I would assume that payment for April 
deliveries was made - accordingly, I would assume that the last payment we 
received from PCA would have been around May 20th).

2.  Total amount of MWH delivered to PCA but for which PCA never paid for.

3.  The details of how you calculated the net MTM exposure of the terminated 
transactions (pursuant to an email to me dated July 27, 1998 you had 
calculated the MTM as of July 7, 1998 at $3,772,939)

As always, thanks for your help.