Subject: Izower Deposition Day 2
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Date: Tue, 5 Sep 2000 13:57:00 -0700 (PDT)

Farallon/Oaktree's counsel, Bruce MacLeod, began his questioning of Izower on 
Friday 9/1.? MacLeod began by establishing that (1) in drafting the offering 
White & Case attorneys relied upon information given to them by the 
underwriters and (2) if the underwriters would have indicated to White & Case 
that information in the offering memo was incorrect, White & Case would have 
changed the offering memorandum.? MacLeod also established that Izower had 
discussed the related party transactions with all of the initial purchasers 
at one point or another.? MacLeod then attempted to revist the issue 
concerning Chanmi's integrity and whether Chanmi's acceptance of kickbacks 
was discussed with the underwriter group.? Izower's counsel refused to allow 
MacLeod to revisit this testimony and McLeod ended his inquiry.

SDI's counsel, Mike Strub, was the only defense counsel to ask questions. (I 
determined that the it made no sense to draw any attention to Enron/ECT given 
that the testimony concerning Enron/ECT had been limited to general 
statements concerning the "underwriters').? Strub attempted to establish that 
SDI was not listed on White & Case's responsibility outline as one of the 
drafters of the offering memo.? Izower agreed that SDI did not initially 
draft the offering documents, but indicated that SDI commented on drafts.? 
Izower also testified that he asked SDI's counsel Bob Walters to review the 
related party transactions section of the memo and to comment on its 
accuracy.? On rebuttal, MacLeod focused on SDI and established that SDI 
reviewed and revised portions of the offering memo. and that Busse attended 
the road shows and never advised Izower that the information contained in the 
memo. concerning SDI's role was inaccurate.

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