Subject: Internal Follow Up at Enron
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked]
Date: Sun, 10 Jun 2001 09:41:00 -0700 (PDT)

Richard and Bill,

The following clean up needs to be done before we finalize our pre-trial
materials due 7/3/01:

          1.  Interview Enron employees Paul Pizzolato, Chris Helfrich, and
Jim Easter to ascertain (a) whether they have sufficient memory of the NSM
transaction that we should add them to our witness list to strengthen our
testimony about the quality and quantity of Enron's due diligence and (b)
whether they have any documents or computer files that should have been
produced earlier in response to the basic document requests in the case. 
(This is not an entirely defensive exercise; Pizzolato or Helfrich might have
computer models that would strengthen our case.)

          2.  Go back to Ray Bowen and find out if he/ECM has documents
relating to NSM.  We asked him before, but he never responded.  Jim Easter
might know the answer to this question, if he is still in ECM

          3.  Talk to Chris Hunt to ascertain whether he or someone else in
his (former?) group should be added to our witness list to discuss due
diligence carried out by Enron International.

          4.  Figure out how we can prove with admissible evidence the precise
amounts of all of Enron's investments in NSM and the identity of the
particular Enron entity making each of those investments.  I have pieced most
of the necessary facts together from McDonald documents and a privileged Akin
Gump memo.  This will not do at trial, unless everyone stipulates to the
facts, which I would not count on.  I know it sounds simple, but we need a
witness on this point and records to back him/her up.

          5.  Consider whether we need to include someone from Bear Stearns,
ECT Securities' clearing firm, on our witness list.  We have to prove that ECT
Securities did not purchase or sell any NSM securities.  Donna Lowry (or
possibly Kevin) may be able to flat out testify to this, but it would be a lot
better to back her/him up with account records.  Donna has recently obtained
the necessary records from Bear Stearns; but, unless everyone will stipulate
to admissibility of these records, I am not sure that Donna alone can get them
in.  We may need a Bear Stearns person.  Maybe we could just list such a
person generically on our witness until we see if the parties will stipulate.

Bill, a number of these matters may still be open when I leave in a week, so
you will have to follow up (unless the 7/3 deadline gets extended on 6/21). 
Jonathan Goldblatt can help.  Typically, Richard likes to talk with any
present or former Enron employee before we do.

Steve

                                                                              

                                                                              

                                                                              

                                                                              
                                                                              
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