Subject: NSM - Claim Filing
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Thu, 3 Aug 2000 17:17:00 -0700 (PDT)

We write further to our telephone discussion with Deb Korkmas this evening
(our time) in relation to the above matter.

As discussed during the course of our telephone discussion, there are a
number of outstanding issues that, bearing in mind the 12 hour time
difference between Bangkok and you and the deadline of the claim submission
which is on Monday 7 August, we would require them to be settled by Friday.

1. Claim amounts
We note from the documentation so far received by us and your e-mail
yesterday that the following entities will claim under the following
agreements:

1.1 Enron North America Corp. wishes to claim for the principal amount
outstanding and the interest outstanding for the Notes under the Security
Purchase Agreement, Indenture and Guarantee.  We would appreciate it if this
could be confirmed and also the definite amount of principal and interest
that is to be claimed.

1.2 Enron North America Corp. wishes to claim for the shares (equity),
as listed in the Shareholders Agreement, held by it in NSM.  However, having
reviewed the documentation so far received by us we are unsure as to the
legal grounds under which Enron North America Corp is entitled to claim this
sum.  Could you please clarify the nature of this claim.

1.3 ECT Thailand Investment Inc. wishes to claim for the shares
(equity), as listed in the Securities Purchase Agreement, held by it in NSM.
However, as in 1.2 above, having reviewed the documentation received by us
we are unsure as to the legal grounds under which ECT Thailand Investment
Inc is entitled to claim this sum.  Could you please clarify the nature of
this claim.

1.4 ECT Securities Limited Partnership wishes to claim for any
contingent liability that they may be subject to as a result of the
litigation undertaken by Farallon Capital, et al. and Legg Mason Income
Trust, Inc., et al.  As discussed, the sums which are allowed to be claimed
have to be fixed sums as of the date on which the court granted an order to
reorganise NSM's business, i.e. 8 May 2000.  It would appear to us that,
asides from the legal fee sums, an exact sum for the contingent liabilities
cannot be ascertained at this time. I would, therefore, appreciate
clarification of how this is to be determined, otherwise the claim amount
may have to be the full potential liabilities as claimed in the two
litigation cases.

2. Documentation
As discussed, we also require the following documentation which we
understand will be faxed to us during the course of today.

2.1 Corporate documents of the 3 entities making claims
2.2 Evidence of the change in the entities name if different from the
name in the relevant agreements
2.2 Debenture Certificate (either global or definitive)
2.3 Evidence of the payment purchase price
2.4 A copy of the Notice of the Event of Default or demand letters as
sent by the Trustee (if any)
2.5 The "Definition and Rules of Usage" as defined in the Shareholders
Agreement (in addition, we do not know whether your claims in relation to
the Shareholders Agreement are related to certain documents as described
therein, e.g. Management Agreement, Enron Purchase Agreement, if they are
related, we would require copies of such agreements as well)
2.6 Tables setting out all amounts (i.e. principal, interest, expenses,
etc.) being claimed by the 3 claiming entities

As mentioned in our discussion, in order to complete the application on time
we would really need to have everything in place by Friday, given the
deadline of the claim submission is on Monday, 7 August.  We would,
therefore, appreciate it if you could reply to all of the above outstanding
issues by today (your time) so that if there are any further outstanding
issues we can try and clarify these during the course of tomorrow (our time)
and perhaps during the weekend.  You may either respond to this email or
alternatively call my mobile phone (661) 619 1262 or Richard Smith's mobile
phone (661) 611 1184.

Best regards

Pichitphon Eammongkolchai / Richard Smith

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