Subject: Citgo Pipeline Rupture Mediation
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Fri, 19 May 2000 06:32:00 -0700 (PDT)

At Kenton's request, I am attaching a copy of the email he sent to the 
parties setting out the general expectations for the mediation.  I am also 
attaching a list of players with as much information as I have been able to 
gather.  This meeting has been set for June 8, 2000 in Houston.  Citgo gave 
me three dates to work with.  At this point the Bechtel group has not 
committed to June 8th date, but it is the only date that all the others are  
available.  The Bechtel group is meeting on Tuesday, May 23 and Jim Johanson 
will notify us thereafter as to their availability on 6/8.  Jim is aware that 
June 8th is the only date the others are available together.    I have not 
heard from the parties regarding how many people from each group will be 
attending.  Robin Jordan, in Houston, has reserved  conference room 45 C-1 
for all day on 6/8.  At the request of John Odam, Robin has also reserved 4 
"break out" rooms for the parties to meet in private during the day as 
business progresses.  She was not able to get all four break out rooms on the 
same floor, but there will be two on the 45th floor and two off the 45th 
floor.  The conference room will have to also serve as a breakout room.  If 
you have any questions, please call Kenton at 503-886-0261 or me at 
503-886-0140.

Email sent by Kenton to all parties:

Enron Broadband Services is hosting a meeting between representatives of 
Citgo Pipeline, Wilde Construction, Bechtel, and EBS, concerning Citgo's 
recovery of all or part of its repair and cleanup costs relating to the May 
1999 rupture of Citgo's pipeline near Luling, Texas.  

In the meeting, which will be handled as a non-binding mediation, each party 
will present its account of what happened,  and the parties will attempt to 
apportion their relative responsibilities for the rupture.  If we all do our 
job correctly, the result will be a written settlement agreement which will 
put this matter to rest.  Mr. John Odam, a Houston attorney experienced in 
pipeline matters and an experienced mediator as well, will serve as the 
mediator during the meeting.  We request that each party share our optimism 
that the mediation effort will be successful, and that we can each avoid the 
higher expenses and endless amounts of time, effort, and uncertainty which 
would be incurred in a lawsuit.

It is imperative that each of you attend the meeting, and that the 
representatives come with authority to bind their companies to pay a portion 
of the repair and cleanup costs.  (If you think your insurance may be 
involved, please fully research your coverage and likely insurance recovery, 
before the meeting.)  Each party is free to bring an attorney, but we ask 
that the attorney be carefully chosen to have a compromising approach, rather 
than a hardnosed "just say no" approach that will just waste our time and 
reflect very poorly on you. 

Would you please quickly tell us all the days, from May 17 through June 30, 
that your representatives are available for this mediation effort in 
Houston?  If you have any questions, please do not hesitate to contact me at 
503-886-0261 (Portland).

Thank you,

Kenton Erwin
EBS in-house counsel

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