Subject: Nolan Deposition: Day 1
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Mon, 17 Jul 2000 15:22:00 -0700 (PDT)

Richard: 

Kathy Patrick began Nolan's deposition today.? It was Nolan's first 
deposition and he seemed a little uncomfortable.? Nolan was overly cautious 
and at times evasive.? The highlights of the day were as follows:

--Nolan did not see the offering memo until he reviewed it on the way to 
Thailand in April '98.? Nolan was not privy to any discussions or road show 
presentations regarding the Notes prior to the closing (When Nolan was 
confronted with communications between himself and Serge Deslise of NSM in 
Jan. '98, he claimed he could not recollect why he would be communicating 
with NSM prior to the closing).

--When Nolan arrived in Thailand, he found a mill that appeared to be state 
of the art, but lacked raw materials and funds to produce steel.

--Nolan soon found that the Mill had serious engineering and management 
problems. 

--NSM had no financial controls until Aug. 98 when Stickler instituted a 
policy of requiring two signatures on disbursements.

Kathy spent a good deal of the day on an e-mail "situation report" sent by 
Nolan to Busse in May '98 discussing numerous problems with the Electric Arc 
Furnace, the Degasser and other parts of the mill.

Enron/ECT came up during the early portion of the deposition.? Patrick asked 
Nolan if he recalls discussing any aspect of the Mill with Brian Barth.? 
Nolan said he could not recall.? Patrick then asked him if he thought? Barth 
was an honest and competent person.? Nolan answered affirmatively.? It 
appears that Kathy is trying to lay the foundation for information she 
received from Brain during her interview. If Kathy continues focusing on 
Brian, however, it may begin to appear quite obvious to the other defendants 
that she has received information from Brian.? 

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